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The effect of customs formalities on the lead time of

hinterland transport

Martijn Thush – August 26, 2018


The effect of customs formalities on the lead time of
hinterland transport

Thesis for the Executive Master of Customs and Supply Chain Compliance

by

Martijn Thush

Academic Supervisor: Prof. Rob Zuidwijk

Co-Reader: Dr. Morteza Pourakbar

Rotterdam School of Management (RSM)

Erasmus University Rotterdam

26 August 2018

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Table of contents

1 Executive summary ..............................................................................................................5

2 Introduction to the research thesis ...................................................................................7

2.1 Customs formalities and hinterland transport of containers.................................... 7


2.2 Problem statement ............................................................................................... 9
2.3 Research scope and objectives .......................................................................... 10
2.4 Thesis outline ..................................................................................................... 12

3 Research methodology and design ............................................................................... 13

3.1 Research concepts ............................................................................................. 13


3.2 Conceptual model............................................................................................... 15
3.3 Research strategy .............................................................................................. 16
3.4 Research stages................................................................................................. 18
3.4.1 Literature review ............................................................................................. 19
3.4.2 Describing the hinterland transportation process ............................................. 19
3.4.3 Data collection ................................................................................................ 20
3.4.4 Analysis of the data ........................................................................................ 20
3.4.5 Formulating conclusions based on the data analysis ....................................... 20

4 Literature review ................................................................................................................ 21

4.1 Supply Chain Management ................................................................................. 21


4.1.1 The importance of intermodal hinterland transport networks............................ 22
4.1.2 Design of hinterland transportation network .................................................... 23
4.1.3 Internal efficiency of network nodes ................................................................ 26

4.2 Trade facilitation ................................................................................................. 28


4.2.1 Definition of trade facilitation ........................................................................... 28
4.2.2 Drivers of trade facilitation .............................................................................. 29
4.2.3 Non-tariff barriers to trade ............................................................................... 30

4.3 Synthesis............................................................................................................ 35

5 Regulatory framework and business process.............................................................. 39

5.1 Regulatory framework for customs formalities ..................................................... 39


5.2 Customs formalities on entry and import ............................................................. 43
5.2.1 Entry Summary Declaration ............................................................................ 43
5.2.2 Entry in the customs territory .......................................................................... 46
5.2.3 Presentation, unloading and examination........................................................ 48

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5.2.4 Temporary storage ......................................................................................... 50
5.2.5 Placing the goods under a customs procedure or re-export ............................. 52
5.2.6 Conclusion ..................................................................................................... 53

5.3 Business process for hinterland transport............................................................ 56


5.3.1 Contract of carriage ........................................................................................ 58
5.3.2 Bill of Lading................................................................................................... 59
5.3.3 Sea Waybill .................................................................................................... 61
5.3.4 Commercial release of containers ................................................................... 62
5.3.5 Conclusion ..................................................................................................... 64

5.4 Planning hinterland transport .............................................................................. 64


5.5 Conclusion ......................................................................................................... 65

6 Data Collection ................................................................................................................... 68

7 Descriptive analysis .......................................................................................................... 71

7.1 First exploration of the dataset ............................................................................ 71


7.2 Association between document lead time and dwell time .................................... 73
7.3 Describing the relation between document lead time and dwell time.................... 74
7.4 The difference between the document lead time and dwell time. ......................... 76

8 Conclusions........................................................................................................................ 81

8.1 Findings and conclusions .................................................................................... 82


8.2 Relevance .......................................................................................................... 83
8.3 Limitations and recommendations for further study ............................................. 84

References ................................................................................................................................... 85

List of figures .............................................................................................................................. 88

List of tables ................................................................................................................................ 89

Appendix A; Example data format for analysis ..................................................................... 90

Appendix B; Terminal procedure RWG for pick up .............................................................. 91

Appendix C; Pre-notification via Portbase ............................................................................. 92

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1 Executive summary

This study is concerned with the effect of customs formalities on the hinterland
transport of containerized cargo. The overarching objective of this thesis was to contribute to
the development of theory regarding the effects of customs formalities on logistics processes,
more in particular the effect on the lead time of hinterland transport. The research objectives
were to find evidence or the absence thereof of the relation between customs formalities and
the lead time of hinterland transport and to identify underlying causes.
In this study the customs- and commercial procedures were dissected out to create
thorough understanding and good overview of relevant processes. Based on this knowledge a
conceptual model was created. Measurable variables for the lead time of customs formalities
and hinterland transport were defined in support of further analysis. “Document lead time”
was introduced to measure the time attribute of customs formalities and “dwell time” was
introduced as a proxy variable for the lead time of hinterland transport.
With support of Rotterdam World Gateway (RWG) and the Dutch Customs
Administration empirical data was collected for further analysis. This data included all the
loaded inbound containers with a destination in the hinterland of terminal operator RWG for
the month September 2017. The data was extracted from the audit file for the temporary
storage facility of RWG and prepared for statistical analysis.
Statistical analysis was performed to answer the question if there is evidence of a
relation between the document lead time and dwell time. The analysis provided evidence that
containers with longer document lead times on average dwell longer at the port terminal. It
was also observed that the time that containers dwell at the port terminal after completion of
the customs formalities is not strongly affected by the speed at which the customs formalities
were completed. Causation was explained based on the qualitative understanding of the
procedures at the port terminal and the legal backgrounds thereof.
This study provides evidence that the time used for customs formalities is an
important factor of influence on the variation in the lead time of hinterland transport. Since
customs declarations compliant with the applicable legal requirements are to be accepted by
the customs administration immediately, this means that the document lead time is driven by
the actions of parties in the hinterland. The underlying cause is the time required by parties in
the hinterland for lodging the customs declaration and for submitting confirmation thereof to
the terminal operator. Cargo interests, directly or indirectly, through parties acting on their

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behalf, influence the time that containers dwell in the port terminal and consequently the
hinterland transport lead time as a whole. Additionally, the uncertainty about the actual
moment that the container will be released by the terminal has the effect that containers dwell
longer at the terminal.
Review of the existing body of academic literature learned that there is great attention
of academics for the optimization of port terminal operations and hinterland transport but that
the link with customs formalities received less attention and is mostly limited to more general
statements. It also revealed that research in the domain of trade facilitation is mostly macro-
economic in nature and does not provide great detail on the actual barriers it tries to
overcome.
The conclusions of this study should raise awareness that customs formalities
influence supply chain performance. Thereby it should also encourage researchers to include
the handling of customs formalities when studying processes related to port terminal
operations and hinterland transport. The findings of this study also give a more detailed view
on a non-tariff barrier to trade, which can be helpful in the domain of trade facilitation. Not
only the procedure itself, but also the way it is handled can form a non-tariff trade barrier to
trade and is therefore relevant to the facilitation of trade.
The findings of this study could support and induce practitioners to improve business
procedures and processes. Driving expeditious handling of customs formalities reduces lead
times of hinterland transport and thereby improves performance of supply chains.

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2 Introduction to the research thesis

This study is concerned with the relation between customs formalities and hinterland
transport of containerized cargo. This introductory chapter first introduces the research topic
(2.1) to give context to this study, after which it will address the problem statement (2.2).
Following clarification of the problem statement, the research scope and objectives (2.3) will
be presented. The last section of chis chapter (2.4) includes an outline of this thesis report for
convenience of the reader.

2.1 Customs formalities and hinterland transport of containers

Figure 1; Development of global container volumes

World trade in goods has increased dramatically over the last decade, rising from
about $10 trillion in 2005 to more than $18.5 trillion in 2014 to then fall to about $16 trillion
in 2015 (UNCTAD, 2016). Similar to the development of world trade, the global
containerized trade has shown considerable growth over the same period, despite the effects
of the financial crisis in 2009 (as can be observed in graph Figure 1; Development of global
container volumes).
Where the maritime industry is often addressed as the backbone of the global
economy, the sea ports and their hinterland connections are an indispensable part of the

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logistics infrastructure just the same. This includes not only the hard but also the soft
infrastructure. Besides the merchants that initiate goods movement, there is a whole range of
service providers involved with transportation and associated activities and auxiliary services.
An international trade transaction between two parties can initiate the involvement of a vast
number of intermediaries. One can think of shipping lines, inland carriers, truckers, seaport
and inland terminals, freight forwarders, banks, customs administration, customs brokers,
distribution centers and warehouses. Although the parties involved may vary considerably
per transaction or per container to be schipped, Oosterhout et. al (2000) give an informative
overview of all parties and the relation between them. Figure 2 sets the scene for this thesis
project.

Figure 2; Layered model of global supply chains (Source: Oosterhout et. al, 2000)

The central theme of this thesis project is the effect of customs formalities on
hinterland transport of containerized cargo. In particular, this thesis project will concentrate
on the inbound flow of containers, from the Port of Rotterdam, at which they arrive in deep
sea vessels, to the hinterland destination of the consignee.

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This thesis attempts to first disentangle the integrated process of customs formalities
and hinterland transport for containerized cargo and then to show how the supply chain and
customs processes are intertwined. This thesis will focus on the effect of customs formalities
on the lead time of hinterland transport. Customs formalities associated with the hinterland
transport of containers from the deep-sea terminals to the hinterland affect the operations of
economic operators and, inversely, the operations of economic operators affect customs
formalities. This project concentrates on this reciprocal interdependency.

2.2 Problem statement

As can be witnessed from Figure 2, international trade is by no means simple. Cross


border transactions involve a wide variety of business actors and governance executives.
Business actors view the international goods flow through the lens of Supply Chain
Management. Their objectives are to create value, enhance efficiency and satisfy customer
needs through management of flows of material, information and resources. The Supply
Chain discipline cuts across networks of upstream and downstream organizations. It is
focused on the alignment with upstream and downstream organizations but takes little notion
of the interaction with governance executives. Although losing time on customs formalities is
particularly undesirable as it translates into reduced competitiveness, there appears to be
limited attention for the time lost in supply chains by customs formalities.
Increased lead times for hinterland transport due to customs formalities do not only
adversely affect the activities of logistics operators for transport and transshipment, also the
trading parties are affected (buyers and sellers of goods). Increased lead times lead to higher
in-transit inventory holding costs and increased delivery lead times and may incur extra
logistical costs such as detention and demurrage.
Expeditious customs handling of inbound containers is beneficial to logistics
operators as well as to the trading parties. Yet, as a result of fragmentation and subcontracting
in the logistics sector, it is often unclear to logistics service providers and trading parties
which effect customs procedures have on the lead time for hinterland transport. This limited
visibility of the time lost may translate in missed opportunities.
The core of the problem is that trading parties and logistics service providers have
little information on the amount of time that is lost in supply chains on customs formalities.
This information deficit limits the opportunity for business actors or groups of business actors

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to develop and invest in proportional improvement actions that effectively drive down the
time lost.

2.3 Research scope and objectives

The overarching objective of this thesis is to contribute to the development of theory


regarding the effects of customs formalities on logistics processes, more in particular the
effect on the lead time of hinterland transport.
This thesis researches the presumptive notion that customs formalities affect the lead
time of hinterland transport processes. The objective of this study is to find evidence -or the
absence thereof- for the association between customs formalities and the lead time of
hinterland transport processes and to describe this relation. This study is not focused on the
procedures and time lost by customs controls, inspections and verification of declarations.
Although customs controls will likely have influence on the hinterland transport lead time,
the effect is not within the scope of this study. The aim is to study the process of customs
formalities on entry. Next to establishing to what extent customs formalities delay hinterland
transport processes, this study will analyze the interplay between business actors and customs
administration to assess the underlying causes for these time effects. In particular the aim is
to highlight where and how time is lost and where subsequently the lead-time for the
hinterland transport is increased.
The focal construct of this research project is the lead-time of the hinterland transport
process from arrival at the deep-sea terminal to arrival at the premises of the consignee. With
reference to this focal construct, the research question is threefold:

- Is there evidence that customs formalities can be associated with the lead time of
hinterland transport ?
- To what extent do customs formalities increase the lead time of hinterland transport
(Days, hours) ?
- Is there a causal effect of customs formalities on hinterland transport lead time ?

Following the research question above, the research objective is to determine if there
is evidence of a relation between customs formalities and the lead time of hinterland transport
of full “inbound” containers arriving in the port of Rotterdam. In case there is evidence of

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such relation between customs formalities and the lead time of hinterland transportation, the
second objective is to understand, describe and explain this relation.

Research objective 1 Time effect of customs formalities

The first objective of this thesis is to determine if there is evidence of a relation


between customs formalities and hinterland transport. As it is safe to say at this stage that
customs formalities will normally not decrease the time required for transport of containers to
the hinterland, the aim is to work out if and to which extend containers are delayed. Because
customs formalities will not influence the time required for the physical transportation itself,
this thesis will focus on the delay that arises during transshipment process from the sea vessel
to the hinterland transport modality.

Research objective 2 Underlying causes

The second objective of this thesis is to describe and explain the relation (if there is
any) to determine the underlying causes for the time lost by customs formalities, regardless if
these causes are to be found within business procedures or in processes of the customs
administration. In particular the focus will be to establish if customs formalities delay
hinterland transport due to late submission of information to the customs administration by
business actors, or due to the procedures for assessing this submitted information.

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2.4 Thesis outline
For convenience of the reader the outline of the thesis is depicted in the diagram
below. The diagram shows the main building blocks of the thesis. Research design and
methodology will be addressed in the next chapter.

Introduction to the research thesis


(introduction of the topic, research scope and objectives)

Research strategy & methodology

Review of supply chain literature Review of trade facilitation literature

(hinterland transport) (concepts and development)

Synthese

Analysis of Regulatory framework and business process

Data Gathering

Descriptive analysis

Conclusion
(summary of results, discussion and further research, limitations)

Figure 3; Thesis outline

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3 Research methodology and design

The object of study for this thesis project is the process of hinterland transportation of
full containers that arrive in the port of Rotterdam. This process entails the transshipment of
containers that have been discharged from container vessels to the means of transport for
hinterland carriage and the subsequent carriage to the consignee in the hinterland.

3.1 Research concepts

The research objective presented in section 2.3 already indicates that this research
project is focused on a specific dimension of hinterland transportation: time. More in
particular it is aimed at the time that passes during hinterland transportation of the container
to the consignee. Within this thesis this time is referenced to as “hinterland transport lead
time”. The hinterland transportation lead time starts at the moment that discharge from the
container vessel is completed and ends at the moment that the container is delivered to the
consignee in the hinterland.
At the heart of this thesis is the underlying presumptive notion that customs
formalities cause variation in the hinterland transport lead-time. It is not the objective of this
study to make statements on the actual hinterland transportation lead time itself, but it is
aimed at the variation in this lead-time. This study therefor concerns itself with the relation
between customs formalities and the variation in hinterland transport lead-time.
As it is safe to assume that customs formalities will not have influence on the actual
transport itself, this research is focused on a sub-process of hinterland transport; the
transshipment process in the port of Rotterdam. The dependent concept is narrowed to the
lead-time of the transshipment process in the port of Rotterdam. Although this limitation
means that the lead-time of the transport itself is excluded from the study, it is still justifiable
to make statements on the variation in lead-time of the hinterland transport as a whole, since
it is inconceivable that customs formalities and the lead-time of transshipment will influence
the speed of hinterland transportation itself. This contraction of the dependent concept also
helps to exclude the confounding variability of the transport lead-time caused by different
destinations of the containers and the average speed of the modality used.
The dependent concept is the variable characteristic of the (narrowed) object of study;
the lead time of the transshipment process. Within the context of this study this lead time

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starts at the moment that the discharge operation of (individual) containers from the deep sea
vessel in the port of Rotterdam is completed. This lead time ends at the moment that the
container leaves the port terminal on the means of transport for inland carriage. This lead
time is generally referred to as “Dwell Time”. The unit of measure for the time dimension of
“Dwell Time” is hours.
The independent concept is the variable characteristic of “customs formalities”. In
this thesis this variable characteristic is the time used to complete the customs formalities.
More specific this is the time used to assign the cargo in the container to a customs
procedure.
In section 5.2 the legal background of customs formalities is discussed in detail and
this section also explains that containers will not be released from the container terminal
before the cargo in the container has been assigned to a customs procedure and the cargo
interest has informed the terminal of this fact. Legally customs declarations can only be
accepted by the Dutch customs administration after the formal act of presentation. In practice
this moment coincides with the actual time of arrival of the container vessel. This means that
it is possible that the terminal receives confirmation that goods have been assigned to a
customs procedure before the container has been discharged from the deep sea vessel.
Because only the time used for completion of customs formalities after discharge of the
container can delay can influence (prolongate) the hinterland transport process, the moment
of discharge of the container is used as the start of the customs formalities. Within the context
of this thesis the formalities are completed when all the goods in the container have been
assigned to a customs procedure and the terminal operator has been informed of this fact
(please find further background in section 5.2).
The independent concept is defined as “document lead-time”. This time starts at the
moment that the discharge operations for a container are completed and ends at the moment
that the cargo interest has informed the terminal operator that the goods in the container have
been assigned to a customs procedure. The unit of measure for this concept is hours.
For better understanding of the definition of both concepts and the relation between
them, Figure 5 is included. Three events on the time axis mark the moments that discharge
operations for a container are completed (discharge), the moment that the cargo interest
confirms to the terminal operator that the goods in a container have been assigned to a
customs procedure (document receipt) and the moment that the container leaves the terminal

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on the means of transport for hinterland carriage (exit). The horizontal arrows are a graphical
representation of the concepts “document lead-time” and “dwell time”
Discharge Document Receipt Exit

Document Leadtime

Time

Dwell Time

Figure 4; Definition of document lead time and dwell time

Although it is a necessary condition that the dwell time is longer then the document
lead time, it is not clear if the document lead time affects the dwell time. Cargo interests or
parties acting on their behalf could use the time available between document and planned exit
randomly to submit the confirmation to the terminal operator that all goods in the container
have been assigned to a customs procedure. In that case there would be only the necessary
condition that the document lead time is shorter than the dwell time, but no probabilistic
relation between the two concepts. Increase in the document lead time would not drive an
increase in the dwell time. It is also possible that the moment of exit is affected by the
document lead time.

3.2 Conceptual model

Based on the foregoing definition of both the dependent and independent concept, a
basic conceptual model is created (Figure 5). The conceptual model depicts both concepts
and the expected causal probabilistic relation between them. The expectation is that the
document lead-time will affect the dwell time of the container. It is a bivariate model with
two continuous variables.

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Customs formalities Hinterland transport

Conceptual Model

Document lead time Dwell time

Figure 5; Conceptual model

The conceptual model comprises three different claims that will be further studied in
this research project.

Proposition 1 The document lead-time and dwell time are related

Proposition 2 When the document lead-time increases, then it is likely that the dwell
time increases

Proposition 3 The increase in document lead-time has causal effect on the increase of
dwell time.

3.3 Research strategy

The preferred research strategy for testing a probabilistic relation between two
concepts (as claimed in proposition 1) is an experiment. (Dul et. al., 2008) As setting up an
experiment for this thesis project is not feasible due to the cost involved, an alternative
strategy was applied to perform this test. The relation between the dwell time and document
lead time is observed in a group of real instances drawn from operational data of a container
terminal. Each instance is defined as a full container arriving at a port terminal with a deep-
sea vessel that will be subsequently transshipped to truck, barge or train for carriage to the
consignee in the hinterland. Based on this data, the existence of the relation will be
researched through statistical testing. In addition, the strength and direction of the association
between the two variables is measured through correlation analysis and by calculation of the
coefficient of determination. Finally, the linear regression equation will be calculated and
interpreted to describe the probabilistic relation between the document lead-time and dwell
time.

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The aforementioned statistical methods can be used to establish the “truth” in
propositions one and two, but not for proposition 3. The statistical evidence of association
between the variables does not imply causation. Proposition 3 will be researched by the
interpretation of the outcome of the statistical analysis and by vetting these outcomes through
qualitative understanding of the process itself. Although this approach cannot produce
conclusive and indisputable evidence of the existence or absence of causation, it will support
the thesis that causation is credible or not. The underlying causes for the time lost by customs
formalities will be identified on the basis of qualitative understanding of the interaction
between customs formalities and hinterland transport.
The underlying causes for delays are identified based on qualitative study of business
procedures and their legal background. Especially customs and supply chain processes and
their legal backgrounds are evaluated to locate where delays arise in the process of hinterland
transportation.

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3.4 Research stages

This research project was conducted in several stages and each of these stages
contributes to the conclusions in this report. This section contains an overview of the
different stages of this research project and makes reference to the applicable chapters. Figure
6 presents a quick overview of the research stages and sections 3.4.1 to 3.4.5 describe the
individual research stages in more detail.

Exploring research topic

Literature review

Building conceptual
model

Describing hinterland
transport and customs
formalities

Data Collection

Analysis of the data

Formulating conclusions

Figure 6; Research stages

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3.4.1 Literature review

The first “port of call” was a review of the existing body of literature. The literature
review (presented in chapter 4) sets the backdrop for this research project. The research topic
was explored through review from two different perspectives.
First, the research topic was explored through review of literature originating from the
supply chain domain. The review was concentrated on the developments of hinterland
transport connections and the operation of port terminals. This review gave an overview of
supply chain literature, focused on the hinterland connection of ports, that helped to
understand what are the current developments, challenges and objectives in the supply chain
knowledge domain.
Second, the research topic was explored through review of literature on trade
facilitation. As trade facilitation concerns itself with removing barriers to trade, it was useful
to understand what drives the trade facilitation agenda and to find out what are the current
objectives and challenges of this discipline and which concepts have been developed to date.
Finally, the most important developments in both knowledge domains were
summarized and the outcome of both reviews was juxtaposed to enable identification of
common ground between the two disciplines and contradictory developments. This also
allowed pinpointing of contradicting views and knowledge gaps between both knowledge
domains. The literature review as a whole served as background to this study and helped to
interpret the findings and conclusions.

3.4.2 Describing the hinterland transportation process

Following the literature review, the relevant aspects of the hinterland transport
process were explored and described (reported in chapter 5). In particular the legal
background of customs formalities and the legal aspects driving the procedures at the port
terminal have been studied. Analysis of the backgrounds of the procedures for releasing
containers by container terminal operators helped to get thorough understanding of the object
of study and to sharpen the research strategy and focus the following stages of this research
project. For the purpose of validation, the outcome of the desk study was discussed with an
EDP auditor of Dutch Customs, the customs coordinator of RWG and a business consultant
of Portbase. The knowledge gained on the background of release process at the port terminal

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supported the identification of data elements that were required for further analysis of the
relation between the document lead time and the time that containers dwell at the port
terminal. Finally, the knowledge obtained in this stage was used in later stages to explain the
results of the statistical analysis of the association between customs formalities and
hinterland transport.

3.4.3 Data collection

With the research strategy in place and with improved understanding of the
backgrounds of the release procedures at the port container terminals, the data elements
required for the analysis of the relation between customs formalities and hinterland transport
could be gathered. Through cooperation with terminal operator RWG and the Dutch Customs
Administration empirical data was made available for this research project. The observational
(secondary) data was drawn from an audit file that is normally used for customs supervision
of the temporary storage facility of the container terminal. The process of collection and
preparation of the data for analysis is further explained in chapter 6.

3.4.4 Analysis of the data

Based on the research objectives, the research strategy, the understanding of customs
and business procedures and the empirical data that was collected, statistical methods were
used to measure the strength and significance of the relation between customs formalities and
hinterland transport and to describe the relation between the two. The analysis is reported in
chapter 7.

3.4.5 Formulating conclusions based on the data analysis

Based on the findings in previous stages, conclusions were drawn and the answers to
the research question were formulated. In addition, the relevance and possible application of
the results, as well as the limitations of the conclusions have been addressed in chapter 8.

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4 Literature review

Following the research design and strategy outlined in chapter 3, this chapter is a
review of the literature that is related to the research topic. This review can draw on a
comprehensive body of literature in both the supply chain management and trade facilitation
domain, but the university-based literature that focusses on customs formalities in relation to
hinterland transport remains meagre. Therefor this review takes a broader scope and the
research topic will be viewed through the lenses of supply chain management and trade
facilitation.
This literature review has a number of aims. Its principle ones are to provide an
introduction to the research topic and to provide context for this study. In section 4.1 the
review will be conducted through the lens of supply chain management and focus on the
development and challenges of the hinterland transport process. In section 4.2 this review
will focus on the definition and the drivers for trade facilitation. In section 4.3 the key
findings from the supply chain and trade facilitation domain will be compared, contrasted and
evaluated. The review as a whole will give understanding of the research topic, challenges in
both domains and a broad overview of what has already been researched. As such, this
chapter provides the wider context within which this thesis project is conducted.

4.1 Supply Chain Management

As already noted in the introduction of this report, hinterland intermodal hinterland


logistics has received generous attention in the academic community, albeit from different
perspectives and on different abstraction levels. In general terms, studies focus on:

- inter-port competition and the importance of hinterland transportation;


- the design of hinterland networks;
- internal efficiency of network nodes (transshipment terminals);
- coordination and planning in hinterland transport chains.

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4.1.1 The importance of intermodal hinterland transport networks

Although the concept “hinterland” is used frequently in day to day speech, it is a


concept that is not easily defined. The hinterland of a seaport is not a static concept with a
fixed delimitation as it is dependent on other factors such as the commodity (e.g,
containerized cargo or bulk) and for example the season. In general terms, the hinterland of a
port can be defined as the area over which a seaport draws the majority of its business
(Notteboom, 2008).
De Langen (2009) introduces the notion that a distinction can be made between
captive and contestable hinterlands. The captive hinterland is the area where the port “is well
established” and the captive hinterland is the area where there is more inter-port competition.
Haralambides (2002) observes that port hinterlands have ceased to be captive and have
extended beyond national boundaries as a result of trade liberalisation, land infrastructure
development and new logistical concepts in the organization of international transport of
containers.
With increasing containerization of international trade, the captive areas have changed
to contestable hinterland with the implication that there is more inter-port competition in the
hinterland of seaports. This increasing dynamic in the hinterland of seaports is well explained
and demonstrated by De Langen (2007).
Over time the increased use of containers in international logistics networks expanded
the hinterland reach of sea ports. (Notteboom 2008). As a result of this development, the
service area of individual sea ports started overlapping and European sea ports are ever more
competing for cargo from the same regional areas. The expanding hinterland coverage
changed the competitive environment from seaports; markets changed from being
monopolistic to oligopolistic to competitive. Notteboom argues that “… the competitive
battle among ports will increasingly be fought ashore. Hinterland connections are thus a key
area for competition and coordination among actors.” The competitiveness of ports is no
longer merely dependent on the strengths and weaknesses of the port itself, it also depends on
the network of which the port is part. The success of a seaport is increasingly determined by
the ability to establish and maintain good quality hinterland connections. Behdani et al.
(2016) build on previous research and confirm that hinterland accessibility and connectivity
are increasingly crucial factors as container transport volumes grow.

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Albeit from a different perspective, the importance of good hinterland connections
was also underlined by Veenstra et al. (2012). They name “unstable hinterland connections”
as one of the factors that created congestion in port facilities when container volumes
increased in the years 2004/2005.
The notion that the hinterland network is an increasingly important factor in inter-port
competition, directly or indirectly induced academics to conduct further research in this field.
This research focused on the design of hinterland transport networks and coordination and
planning in hinterland transport chains

4.1.2 Design of hinterland transportation network

Notteboom (2008) observes that “…the success of a port depends on the ability to
integrate the port effectively in the networks of business relationships that shape efficient
supply chains, and to exploit synergies with other nodes and other players in the hinterland
network”. Van der Horst et al. (2008) argue for the need to analyze the coordination in
hinterland transport. In general (not specific to different modalities) they identify that
coordination problems in the hinterland chains arise because of an imbalance between the
costs and the benefits of coordination, a lack of willingness to invest, strategic considerations
of the actors involved and risk-averse behaviour. They present a scope change for actors in
the chain as one of the possible mechanisms to enhance coordination. This scope change
includes more hierarchical coordination and vertical integration in the transport chain. An
example of this vertical integration is a seaport terminal operating company that invests in
inland transport and inland terminals. In line with this suggested enhancement for hinterland
transport coordination, Roso et al. (2009) observe that “ports have shown interest in starting
inland terminals in order to control and optimize a larger part of the intermodal transport
chain.” Through investments in inland connections, terminals have local presence and can
exert control over hinterland transport operations and have figuratively moved the terminal
gate to the hinterland. A form of vertical integration is the dry port, which can be defined as
an inland intermodal terminal directly connected to seaport(s) with high capacity transport
mean(s), where customers can leave/pick up their standardized units as if directly to a seaport
(Leveque et al. 2002). The theory entails that the shipper or forwarder see the dry port as an
adequate interface with the port and the shipping lines. In that sense, the dry port goes
beyond the conventional utilization of an inland terminal. Roso et al. (2009) argue that as a

23
result of consolidated goods flow between the sea port and the dry port there is room for
other traffic modes to be used. They come to the conclusion that dry ports enable sea ports to
secure market in the hinterland, increase the throughput without physical port expansion and
provide better services to shippers and transport operators.
Veenstra et al. (2012) explore the relation between the concepts of extended gate and
dry port. They observe that in practice dry ports in do not live up to the premise of Leveque
et al. (2002) but more often function as normal inland ports without centralized control over
the goods flow between the seaport terminal and inland terminal. Veenstra et al. (2012) signal
that one of the main the challenges is the modal split requirement for new terminals in
Rotterdam. Through analysis they come to the conclusion that utilization of more scheduled
barge and train services must be accompanied by more control over the flow of containers
into the hinterland in order to uphold the performance perceived by sea vessel- and hinterland
mode operators. Subsequently they address that another important issue is the identification
of the party that assumes responsibility for transportation between the port and the inland
terminal. When the sea port terminal operator coordinates the movement of goods between
the port and the inland terminal this also implies that the terminal either assumes
responsibility directly or asks a third party to assume responsibility. Finally, they name the
availability of “the right information” as a crucial condition for efficient hinterland networks.
All in all, they conclude that the extended gate concept is in theory not fundamentally
different from the dry port, but that the extended gates should fulfill the initial ambition of the
dry port concept in practice. Against the background of the research project at hand it is
worth mentioning that one of the elements of the future vision of Veentstra et al. (2012) on
hinterland networks is that inspection and supervision regimes of Customs and other
government inspection agencies will be moved into the hinterland and that the administrative
processes in the port itself need to be “completely optimized”.
The dry port and extended gate concept are primarily based on vertical integration of
activities in the intermodal transport chains. These concepts introduce a centralized
coordination of intermodal transport services in the hinterland. With synchro modal freight
transport, cross-modality, also known as horizontal integration, is added. Cross-modality
includes the use of multiple modalities alongside each other in order to take advantage of the
complementary nature of the different modalities. Cross modal transport services allow trade-
off between service and cost aspects (Behdani et al. 2016). Both horizontal and vertical
integration of intermodal transport services are depicted in Figure 7 below.

24
Figure 7; Integrated view of freight transport planning (Behdani et. al, 2016)

Synchromodality includes vertical integration to synchronize moving and stationary


resources (terminals and means of transport) as well as horizontal integration to synchronize
the operation of multiple modalities (truck, barge train) as a “single transport service”.
Behdani et al. (2016) note that: “the additional level of integration in this service is expected
to improve the performance of the whole transport system and results in increased utilization
of transport means. It also stimulates the optimal use of all modes of transport, which might
lead to a stronger position for intermodal freight transport”. The integration also calls for new
business models and commercial propositions, because one party in the transport chain will
act as integrator for the service. An example is the concept of terminal haulage in which the
Sea port terminal coordinates transport to and from the hinterland. Behdani et al. (2016) also
present a mathematical model for operational schedule design that is expected to assist the
planning function to determine an optimal schedule of multiple transport modalities in
intermodal transport services within a fixed timeframe.
From the literature it is clear that the need for efficient hinterland transport networks
is recognized and that the ability to integrate the port in efficient hinterland networks is seen
as a competitive strength. Although the hinterland network and service design received much
attention from the academic community, actual implementation of true intermodal networks
and services is lagging behind. The cited studies indicate that there is a need for better
integrated intermodal services with more centralized coordination to synchronize terminal
and hinterland transport operations and to use the most efficient mix of modalities.
Academics propose concepts like dry port, extended gate and synchro modality, all of which
are focused on strengthening and integration of transport services. It appears that the research
is predominantly positioned to address the challenges of logistics service providers in the
supply chain and to lesser extend pay attention to the viewpoint of consignors and
consignees. The availability of up to date information for planning and coordination to

25
transport and transshipment operators is seen as a prerequisite for the operation of effective
and efficient hinterland networks. In the literature in the supply chain domain there is little
attention for the integration of logistic activities with customs formalities.

4.1.3 Internal efficiency of network nodes

Driven by growth in world trade, transshipment of containers in seaports has also


grown considerably. In the years from 2005 to 2015 the total transshipment volume for
containers in the port of Rotterdam has grown with 25% despite the global crisis that started
in 2007 (source: http://monitor.topsectorlogistiek.nl, visited 14 July 2017). In response to to
the growing volumes, terminal operators, shipping lines and port authorities are investing in
new technologies to improve operational efficiency of container terminals. Another aspect
that calls for increasing efficiency in port terminals is the increased capacity of container
vessels. Over time the vessel size has increased, resulting in larger call sizes at ports. Since
these large vessels can only berth in ports with adequate draft and port facilities, the number
of calls per voyage has been reduced and consequently the drop size per call has increased.
As a result, larger ships spend more time in a port than smaller ships. (Gharehgozli et al.,
2016).
Crainic and Kim (2007) consider that the three main activities in port terminals are:
berthing and loading and unloading of vessels, receiving and delivery operations for trucks
and trains and finally container handling and storage operations in the yard. Cranic and Kim
(2007) give an overview of strategic planning issues for container terminals in the investment
phase and corresponding models for operational planning and control.
Strategic planning for investments in port terminals includes planning issues related to
the number of berths (quay length), the size of storage space and the equipment to install.
First, container vessels have high investment and operational costs and waiting time is
expensive. Consequently, strategic planning will involve balancing the turnaround time of
ships with the berth construction and operation costs. The second important strategic
planning issue is the number of quay cranes to be installed. Throughput rate is to be balanced
with the investment in capital intensive quay cranes. Finally, strategic planning involves
planning of the required container storage space. Available storage space will influence the
height of storage stacks. When the space becomes smaller the container stacks will be higher,

26
resulting in lower productivity in the container yard. Consequently, the investment in storage
space must be balanced with productivity of the transfer operations in the container yard.
Following the elements of strategic planning of port terminals, academics have given
attention to models for operational planning and control. Amongst others, these models
address berth allocation and quay crane planning, stowage planning, and storage planning.
Various models for the berth allocation problem minimize the sum of ship handling and
waiting times whilst taking into account different variables, such as service costs of ships,
tidal constraints, fuel consumption of the vessel. The quay crane assignment problem is
optimized with models that maximize crane production through reduction of the number of
crane setups and travel times. For the quay crane scheduling problem models were developed
to produce optimal schedules that can maximize the throughput of containers and minimizing
the loading / unloading time (makespan) whilst satisfying constraints arising from the
physical infrastructure (e.g. the cranes are on the same track and require a minimum distance
between them) or from other planning aspects.
From the work of Crainic and Kim (2007) Cochrane (2008) and Gharehgozli et al.
(2016) becomes clear that the in the past decade the academic community has produced a
sheer avalanche of academic literature on operations research models and methods for the
optimization of container terminals. This research is predominantly driven by growing
container volumes, inter port and terminal competition and the introduction of bigger deep-
sea container vessels. The literature provides models and methods to maximize the demand
satisfied, enhance operational efficiency, avoid of congestion and waiting time in the port.
Operational challenges are mostly addressed in isolation, and the main focus of the solutions
and recommendation provided is on internal processes of the terminal itself.
Interestingly enough, Ypsylantis (2016) takes a different perspective and challenges
the general view that the operational performance of container terminals is purely reliant on
endogenous factors. In his study, he singles out the time that containers dwell in the port
terminal. He aims to determine the main drivers of container dwell times and to propose
measures to reduce them. Ypsylantis (2016) challenges the general view, expressed in
previous studies1, that dwell times can be treated as a purely endogenous capacity
performance criterion. Contrary to previous studies, Ypsilantys (2016) argues that dwell

1
Little and Graves (2008), Chu and Huang (2005), Steenken et al. (2004), Cochrane (2008)

27
times are affected by exogenous factors. He proposes that shippers’ preferences affect the
dwell time at the sea terminal. He identifies shipper effects, such as; selection of deep sea and
inland carriers by the shipper, value and time criticality of the cargo, supply chain design and
information availability, as candidate determinants for container dwell time.
For the data used in the study, statistical analysis of transactional data shows that the
identity of the shipper has effect on the dwell time. In addition, Ypsylantis motivates that
three possible determinants, directly connected to the shipper, also have a significant effect
on the dwell time, being modality for inland transportation, the time of booking with the
inland carrier and time criticality of the container. Shippers that place orders for inland
carriage in advance of container discharge at the seaport more often realize shorter dwell
times at the sea port.
Ypsilantys (2016) concludes that it follows from previous literature that container
dwell times can be reduced through improved operational performance of the container
terminal but adds his own conclusion that dwell times can also be reduced by motivating
other actors such as shippers, shipping lines, inland carriers and inland terminals “to act
towards this enhancement”.
In conclusion it is clear that, driven by growing volumes of containers to be moved,
increased vessel capacity and inter port and terminal competition, the academic community
produced operations research models and methods to support planning and coordination on
strategic, tactical and operational level. Research over the last decade is mainly focused on
problems and challenges in isolation and the solutions and recommendations are logically
focused on aspects that can be controlled by terminal operators themselves. Examples are
optimized berth planning, quay crane allocation and sequencing, methods to organize
container stacks etc. Recent literature calls for more integration of models and methods and
addresses that the performance of port terminals does not only depend on endogenous factors
but that exogenous factors are also determinants for operational performance.

4.2 Trade facilitation


4.2.1 Definition of trade facilitation

Trade facilitation is by no means a new phenomenon. The preamble of the General


Agreement on Tariffs and Trade (WTO, 1947) makes note of the desire to reduce tariffs and
other barriers to trade for the purpose of making full use of the resources of the world and the

28
expanding of production and exchange of goods. These “other” barriers to trade are the non-
tariff barriers that hinder or restrict cross border trade.
Various studies and publications (Wilson et al. 2005, Grainger 2007, Grainger 2014,
EU 2015) make an effort to define trade facilitation. Grainger (2007) explains that “trade
facilitation looks at how procedures and controls governing the movement of goods across
national borders can be improved to reduce associated cost burdens and maximize efficiency
while safeguarding legitimate regulatory objectives”. The EU defines: “Trade facilitation
involves measures to simplify, modernize and harmonize import, export and transit rules and
procedures, as well as - importantly - customs requirements, all intended to ease trade flows.”
Although the nuances in definitions vary to some extent, the common denominator is that
trade facilitation seeks to simplify and harmonize customs procedures associated with
movement of goods in international trade to improve the trade environment.

4.2.2 Drivers of trade facilitation

Following 1994, when the revised General Agreement on Tariffs and Trade
superseded the original agreement, the international tariffs on trade have fallen. From 1
January 1995 onwards, developed countries cut their tariffs on industrial products with 40%,
from an average of 6.3% to 3.8%. The value of industrial products that receive duty free
treatment increased from 20% to 44%1. Granger (2011) observes this as turning point in
international trade policy. Stimulated by substantially reduced tariffs, trade policy is
increasingly focused on the non-tariff barriers to trade. Both Engman (2005) and Grainger
(2011) discuss developments that drive the increasing attention for trade facilitation.
Next to falling tariffs and the pressure from international trade negotiations, Granger
(2011) identifies two other systemic factors that underlie the renewed attention for trade
facilitation.
Firstly, growing volumes of trade and increased political pressure to accommodate
tighter security in the wake of the 9/11 terror attacks, presented new operational challenges to
border agencies. This development called for more effective application of border controls
without impeding the movement of global trade. New standards for control (SAFE

1
https://www.wto.org/english/thewto_e/whatis_e/tif_e/agrm2_e.htm, accessed 20 July 2017

29
Framework of standards, AEO, C-TPAT) that have been implemented since, recognize the
need for collaborative control agreements with business that are incentivized through trade
facilitation. At large, these collaborative control agreements entail that economic operators
that can demonstrate effective compliance management are considered trusted partners of the
customs administration and receive benefits that simplify procedures or expedite cross border
transactions.
Secondly, an argument for trade facilitation is the desire to improve national
competitiveness. Grainger (2011) reasserts WTO publications that non-tariff barriers will
place business stakeholders at a disadvantage. Table 1 summarizes the developments that
drive trade facilitation based on Engman (2005) and Grainger (2011)
With respect to the last factor, national competitiveness, academic literature
proclaiming positive impact of trade facilitation is very abundant. Engman (2005) draws on
an anthology of previous research and finds that all the studies surveyed indicate a positive
relation between trade facilitation and trade.

Developments driving trade facilitation (combined from Engman (2005) and Grainger
(2011))

Reduction of tariff levels, increasing the focus on non-tariff barriers to trade

Reduced transportation costs, lean production and reduced inventory levels have made
companies dependent on more frequent and reliable delivery of small batches of
intermediary inputs.

Pressure stemming from international trade negotiations and the Trade Facilitation
Agreement

Customs administrations respond with collaborative control agreements in combination


with trade facilitation to confront operational challenges resulting from larger trade
volumes and political pressure to accommodate tighter security controls

Heightened visibility of trade transaction costs by multinationals, increasing the pressure


from the business community on border control agencies

Recognition of trade facilitation as an instrument to increase national competitiveness

Table 1; Developments driving trade facilitation

4.2.3 Non-tariff barriers to trade

As follows from the definition of trade facilitation it is aimed at reducing the none
tariff barriers to international trade. This objective cannot be achieved without identification

30
and understanding of the barriers that it tries to overcome. Most of the academic literature on
trade facilitation is economically flavoured and seeks to identify the macro economic impact
of trade facilitation or the determinants for customs related transaction costs.
Verwaal and Donker (2003) study the relation between customs related transaction
costs, firm size and trade intensity. The study identifies the determinants of customs related
transaction costs and the effect of transaction costs on the intensity of international trade of
firms.
Empirical results show that the size of the firms has no significant effect on customs-
related transaction costs. Different from the size of the firm the cross-border transaction
frequency and size of the individual transaction do have significant effect on customs related
transaction costs. This supports the idea that the scale in which a firm is engaged in cross
border transactions is an important determinant of customs related transaction costs.
Economy of scale can strongly reduce customs related transaction costs.
Further results show that a simplification such as monthly filing or increased use of
information technology are effective methods to reduce customs related transaction costs.
Furthermore, the results of the study show that customs related transaction costs repress the
international trade activities of firms.
The researchers suggest that firms can reduce the burden of customs related
transaction costs by consolidating shipments, the use of simplified customs procedures and
the advanced use of information technology. For customs authorities, they indicate that the
facility of simplified procedures are an effective method to reduce customs related
transaction costs but that the conditions to obtain licenses for these simplifications favour
larger firms. Although this study gives good insight in determinants for trade barriers proxied
by transaction costs, it does not specify which customs related activities or operational
frustrations do make up these costs. It does not help to understand what is the actual barrier to
trade.
The OECD (OECD, 2013) published a policy paper that sheds some light on the
barriers to trade. This paper synthesizes earlier work of the OECD to increase understanding
of the trade costs across the entire trade chain. Although trade costs are not synonym to actual
trade barriers, they can be seen as a quantitative proxy of process “frustrations”.

31
Figure 8; Trade cost diagnostics (Source: OECD, 2013)

Figure 8 above provides a narrative storyline of what the hurdles are for traders in the
international trade chain, sequentially from exporter to the importer. The figure distinguishes
three stages in the trade chain, being “getting to the border”, “at the border” and “behind the
border”. The middle stage “at the border” includes the tariff barrier and the non-tariff barriers
that trade facilitation seeks to reduce. The direct costs consist of duties to be paid (tariff
barrier) as well as all costs that can be directly related to customs formalities such as lodging
declarations, providing certificates of origin, legalization of documents etc. (non-tariff
barrier). The indirect transaction costs are associated with the time required for border
crossing. It includes all procedural delays, inventory holding costs and opportunity costs
induced by the time required for customs formalities. Goods, such as perishable products can
be depreciated because of stoppage at the border, or traders can lose business opportunities.
Business opportunities may be lost because capital is tied up in pipeline stocks diverting it
from other productive application.
The OECD estimates that direct trade transaction costs amount between 2% and 15%
of the value of the traded goods, whereas the indirect trade transaction costs range between
1% and 24%. Although the range of both estimations is quite broad, the OECD indicates that
simulations learned that indirect costs “would be by far the greatest contributors (up to 80%)

32
to the welfare gains associated with a reduction in overall trade costs at the border” (OECD,
2013).
From the OECD policy paper we can learn that the non-tariff trade barriers at the
border consist of (1) work that is needed to collect the relevant data, process relevant
information, produce all documents, and to communicate the relevant information and
documents to customs to satisfy all legal requirements, (2) time that the goods are delayed as
a result of the formalities at the border, and (3) money to cover for the risk of predation, theft,
bribery and “facilitation payments”. The factor time “time” would be the greatest contributor
to cost reductions at the border.

Figure 9 From cost components to trade diagnostics (Source: OECD, 2013)

Another important element of the conclusion is that trade transaction costs in a single supply
chain are interrelated. The OECD states as an example that “improvements in hard
infrastructure such as railroads cannot translate into time savings if not accompanied by
efficient logistics services, professional customs officials, and adequate competition in
transport services.” Targeting specific cost elements in isolation could give rise to a shift
between cost elements rather than achieving the objective to reduce the total trade transaction
costs. Consequently, the OECD calls for a holistic approach when addressing trade costs and
facilitating trade.
The OECD presents a diagnostics framework (See Figure 9 above) to identify the
most binding constraints. This framework should help policy makers to find the primary and
underlying causes of trade transaction costs. The framework helps to narrow down cost
drivers along the trade chain that should receive most priority and that can be directly
targeted with measures of trade facilitation. The framework is essentially a top-down

33
sequence of questions to locate the problem area where trade facilitation would bring the
biggest return.
Grainger (Grainger, 2014) observes that most of the research in the field of customs
and trade compliance is limited to macro-economic models and international surveys. Over
time a significant body of literature has been produced by proponents of trade facilitation that
seek to encourage wider economic development through trade facilitation. This macro-
economic approach is helpful to raise awareness for the importance of trade facilitation, but
due to the lack of operational context and detail it is difficult to use these research findings to
plan and implement meaningful improvements to facilitate trade.
Grainger (2014) continues with a more “bottom-up operations-informed approach” to
trade and customs compliance costs at sea ports. He reflects upon the valid legislation and
administrative practices and attributes compliance costs to three categories, being: (1) the
initial setup and authorization costs (2) transaction type costs and (3) the costs associated
with physically presenting and inspecting goods. Subsequently he provides a descriptive
account of which trade and customs related accounts in each category.
Veenstra (2015) argues that disruptions in the physical and administrative operations
of ocean shipping are a barrier to trade since they cause delay, uncertainty and additional
costs. Veenstra presents a descriptive account of “ocean shipping transactions” and
characterizes the frictions in international trade transactions within the methodological
framework of transaction cost economics. Against the backdrop of this theory of transaction
costs economics, Veenstra observes that international trade transactions related to ocean
shipping are almost completely market based due to a low degree of asset, site and human
specificity. Site specificity refers to “core technology” that is crucial to the transaction. Asset
specificity refers to the degree to which the assets are specific to the transaction. Human
specificity refers to special knowledge that is required for the transaction. Because the the
specificity of the named aspects is low, the links between the various actors are
predominately contracting relationships between firms, instead of internal firm procurements.
Veenstra cites Williamson (1981) arguing that the benefit of this market relationships is that
scale economies in assets can be fully utilized and that uncorrelated demand can be
aggregated. Inversely, drawbacks can be sub optimization in parts of the transaction, costly
conflict resolution, poor access to relevant information for settlement of disputes or
measurements of performance. Veenstra studies the different elements of the trade
transaction in more detail and measures the magnitude of the frictions manifested as

34
uncertainties (time) and additional costs. In particular he focusses on pre- and on carriage,
container release at the port terminal, and the formalities related to supervision. Based on a
“first estimate”, Veenstra concludes that the uncertainties that follow from these processes
(delays, additional time required for supervision) by far outweigh the additional costs. Insofar
this conclusion echoes the conclusion of the OECD discussed previously in this chapter.
Veenstra argues that the reduction of the lead time of containers in the transport chain can be
achieved by (1) reducing the delay of vessels in the port (2) Reducing the time containers
spend in the port (3) improved information provision by customs on the release status of
containers in the port. In addition, Veenstra returns to the theory transaction cost economics
and concludes that removal of time frictions is also the basis for partial network integration
initiatives that can be observed in practice.
In conclusion, it becomes clear that the concept of trade facilitation has been around
for decades. Already in 1947 it was noted that reduction of tariffs and non-tariff barriers to
trade could lead to more global economic prosperity. Nations have successfully reduced the
average level of duties to be paid to stimulate international trade. Amongst a handful of other
reasons this development has led to an increased focus on the possibility of reducing non-
tariff barriers to trade. Macro-economic studies have underpinned the case for trade
facilitation but have proven to be of limited value to shape the trade facilitation agenda itself.
Self-evidently macro-economic analysis falls short of operational detail that is required to
enhance understanding of the barriers to trade in an operational environment. Further
research produced the understanding that the indirect costs at the border are related to delays
and uncertainties and outweigh the direct costs associated with formalities at the border.
Whereas the OECD presents a framework to dissect primary and underlying causes for high
trade costs, other researchers call for an operations informed bottom-up approach to identify
the non-tariff barriers to trade. Existing literature makes a first assessment of the magnitude
of frictions at the border, but more detailed and comprehensive research of the actual non-
tariff barriers at the border could not be found.

4.3 Synthesis

Within the context of this research assignment literature from the trade facilitation
and supply chain domain was reviewed to shed light from different sources on the
streamlining of the container flow into the hinterland. Table 2 (page 38) is the juxtaposition

35
of the literature from both research domains that was reviewed. Although both domains seek
to ease trade and goods flow, differences in objectives, drivers, research focus, solutions and
audience are easily distinguished.
Studies in the supply chain management domain mostly take the perspective of
logistic service providers. Researchers seek to cure competitive deficiencies of logistic
service providers in hinterland transport networks. As we have seen this research is propelled
by growing volumes of containers, growing capacity of deep sea vessels, congestion and
efficiency problems. Literature proposes collaborative arrangements to integrate processes of
commercial parties in the hinterland, concepts for network and service design and operation
research models to optimize planning in transshipment in nodes.
It appears that the researchers are more concerned with the challenges of logistics
service providers than with the opportunities for consignors and consignees. The impact of
customs formalities and the interaction with government actors in the hinterland transport
process is scarcely acknowledged within the realm of supply chain management. In the
supply chain literature, there is little attention for the impact of customs formalities on
hinterland transport.
Following from the broader scoped objectives of trade facilitation, literature from this
domain is predominantly focused on macro-economic effects. It seeks to initiate regulatory
reform to reduce frictions at the border to stimulate international trade. Through macro-
economic research, academics have propped up the advantages of reducing the non-tariff
barriers to trade. Different sources make the analysis that the indirect costs are associated
with time and uncertainty of border formalities rather than with the direct costs that can be
associated with the administrative work in connection with customs formalities. Although
trade facilitation has made its way up on the agenda of policy makers, there is hardly any
literature that gives a better view on the operational obstacles caused by customs formalities
related to cross border trade. While the rationale for trade facilitation is compelling, lack of
detailed understanding of the actual operational problems is preventing the conversion of
intentions to facilitate trade into practice.
From the criticism above it becomes clear that there is a disconnect between the two
knowledge domains. Whereas the supply chain domain fails to take account of customs
formalities in the supply chain, the trade compliance domain fails to integrate the operational
detail from the supply chain knowledge domain. The solutions of the supply chain are wasted
when containers are delayed by lengthy customs formalities while conversely substandard

36
supply chain processes will cancel out the positive effects of trade facilitation. This
disconnect demonstrates the need for a more holistic and integral approach in which the
knowledge and solutions of both domains are combined to one and calls for better
understanding of the integration of supply chain processes with customs formalities.

37
Supply Chain Management Trade facilitation

Objective • Increasing the ability to integrate the • To reduce tariffs and other barriers to trade for
port effectively in the networks of the purpose of making full use of the
business relationships that shape resources of the world and the expanding of
efficient supply chains, and to exploit production and exchange of goods
synergies with other nodes and other
players in the hinterland network.

Drivers • Growing container volumes. • Increasing focus on non-tariff barrier to trade


following the reduction of tariffs.
• Increasing vessel capacity.
• Introduction of collaborative control
• Inter port competition. agreements.

• Recognition that hinterland • Pressure stemming from international trade


accessibility and connectivity are negotiations and the Trade Facilitation
increasingly crucial factors as Agreement.
container transport volumes grow.
• Heightened visibility of trade transaction costs
by multinationals, increasing the pressure
from the business community on border
control agencies.

• Recognition of trade facilitation as an


instrument to increase national
competitiveness

Research focus • Efficient utilization of assets in ports, • Macro-economic analysis to underpin the case
such as quays, cranes, stacks etc. for trade facilitation.

• Coordination of different operators • Development of frameworks to explain non-


and activities in the hinterland. tariff barriers to trade.

• Optimized utilization of transport


modalities (modal split).

Solutions and • Planning algorithms to advance • Development of diagnostics framework to


concepts efficient utilization of assets in ports. identify the most binding constraints and
underlying causes
• Horizontal and vertical integration of
logistic services in the hinterland.

• Service network design

• Concepts such as: Dry port, Extended


gate, Synchromodality.

Audience • Business community, actors in the • Government policy makers


logistics sector

Table 2; Comparison literature in Supply Chain and Trade Facilitation domain

38
5 Regulatory framework and business process

This chapter describes the customs regulatory framework and business processes for
containerized cargo arriving at the port of Rotterdam. The aim of this chapter is to untangle
the strands of customs procedures and business processes and to subsequently model the
integrated process to the extent necessary for the achievement of the research objectives.

5.1 Regulatory framework for customs formalities

This section focuses on the legislation that forms the regulatory framework for
customs formalities on entry and import of containerized cargo into the EU customs Union.
Before turning to the legislative acts regulating the customs formalities on entry, this section
first reviews the legal basis for these acts, starting with the primary law of the European
Union.
Figure 10 depicts that Union law is based on primary and secondary legislation.
Primary legislation includes the Union Treaties, general principles that are established by the
Court of Justice of the European Union (CJEU) and international agreements. Secondary
legislation includes all the acts that implement the policies in the treaties and which enable
the EU to exercise its powers.

Union Treaties
Primary legislation General Principles of Law
International agreements concluded by EU

Legislative acts (Regulations, Directives, Decisions)


Secondary legislation Non-legislative acts (Delegated acts, Implementing acts)
Other acts (recommendations, opinons, etc.)

Figure 10; The sources and hierarchy of EU Law (European Customs Code, Tom Walsh)

39
The legal foundations of the European Union are the Treaty on European Union
(TEU) and the Treaty on the Functioning of the European Union (TFEU). With the treaty of
the European Union, the contracting parties have established the European Union (hereafter:
the Union), on which the Member States have conferred the competences to attain objectives
they have in common (TEU Article 1).
One of the common objectives of the Union is to “work for the sustainable
development of Europe based on balanced economic growth and price stability, a highly
competitive social market economy, aiming at the full employment and social progress, and a
high level of protection and improvement of the quality of the environment. It shall promote
scientific and technological advance”. The internal market is presented as a means to this
end. (TEU Article 3).
The internal market comprises an area without internal frontiers in which the free
movement of goods, persons, services, and capital is ensured (TFEU Article 26). Since the
free movement of goods applies to all goods, including goods imported from non-EU
countries, there is a need to harmonize the rules for trading with countries outside the internal
market to overcome distortion of competition resulting from variation in rules for trading
with third countries. To achieve this necessary harmonization, article 28 TFEU establishes
the Customs Union and additionally this article sets out the principal elements of this
Customs Union. The main features of this Customs Union are the prohibition to levy customs
duties or charges with equivalent effect on trade between Member States and the adoption of
a common customs tariff for trade with third countries.
The TFEU determines the areas of, delimitation of, and arrangement for exercising
the competences conferred on the Union. It arranges the division of competences between the
Member States and the Union and emphasizes that competence is granted to the Union on a
limited basis and that the residual power remains with the Member States. When it comes to
the Customs Union, article 3 TFEU provides that the customs union falls within the exclusive
competence of the Union. This means that only the Union may legislate and adopt legally
binding acts in this policy area and that Member States may only act where they are
specifically empowered by the Union to do so (Article 2 TFEU). While the constitutional
treaties are silent on the issue of which law should take priority in case of conflict, the
European Court of Justice (ECJ) has filled this gap with case law (cases Van Gend den Loos,
Costa, Simmenthal). The ECJ identified the Union as independent legal order, supreme over
the national legal systems of the Member States. The ECJ reasoning on supremacy of EU law

40
is best explained in the Costa case. The court ruled in this case: “Such a measure cannot be
inconsistent with that legal system. The executive force of Community law (now Union)
cannot vary from one State to another in deference to subsequent domestic laws without
jeopardizing the attainment of the objectives of the Treaty… The obligations undertaken
under the Treaty establishing the Community (now Union) would not be unconditional but
merely contingent if they could be called into question by subsequent legislative acts of the
signatories…”
Figure 10 depicts that international agreements are part of EU primary legislation.
The Union may conclude agreements with one or more third countries or international
organisations and the agreements concluded by the Union are binding upon the institutions of
the Union and on its Member States (TFEU article 216). This means that international
agreements are an integral part of the Unions legal order and have to be respected by the
Institutions and the Member States of the Union. Where rules in international agreements are
sufficiently clear and precise, they do not need to be transposed into secondary legislation to
allow application. Examples are preferential trade agreements and the TIR convention.
Where international agreements are less precise and allow larger margins of choice by
contracting parties, transposition into secondary legislation is needed. Different mixed
methods for the implementation of international agreements can be distinguished, depending
on the nature of the international agreement or the intentions of the contracting parties.
Against the backdrop of this study no relevant directly applicable international agreements
have been identified.
Secondary legislation of the Union is adopted through the law-making processes of
the Union and enables the Union to exercise the powers conferred on it. To exercise the
exclusive competence in the policy area of the Customs Union (TFEU article 3), the
institutions of the Union adopt secondary legislation, including regulations, directives,
decisions, recommendations and opinions (TFEU Article 288). A regulation has general
application and it is binding in its entirety and directly applicable in all Member States. A
regulation does not require further implementation to take effect.
Within the policy area of the customs union the Union has adopted regulation (EU)
No 952/2013, the Union Customs Code (UCC hereafter). This legislative act, that has a legal
basis in the primary law of the Union and enshrines the basic legislation on the principles and
functioning of the customs union, has been adopted by the Council and the European
Parliament through the ordinary legislative procedure as set out in Article 294 TFEU.

41
The TFEU provides in article 290 and 291 that a legislative act may delegate to the
commission the power to adopt non-legislative acts to supplement or amend non-essential
elements of the legislative act. This provision helps to prevent that the legislative system is
clogged up with matters of detail. Through multiple articles, as listed in article 284 of the
UCC, the power to adopt non-legislative acts is delegated to the commission. On the basis of
this delegation the commission has adopted Commission Delegated Regulation No
2015/2446 (UCC DA hereafter). In addition to the UCC DA, the commission adopted
Commission Delegated Regulation No 2016/341, including transitional rules for the time that
relevant IT systems are not yet operational (Hereafter UCC TDA).
The power to adopt implementing acts is conferred on the commission through the
UCC (Article 281). Based on this conferral of power the commission adopted Commission
Implementing Regulation No 2015/2447. The preamble of this regulation reads: “to specify
the procedural rules for some of its elements, in the interest of clarity, precision and
foreseeability”
As explained, customs law in the EU is to a large extent enshrined in the Union legal
order. National (customs) law primarily contains provisions for implementation of Union
customs law, insofar Member States are specifically empowered by the Union to do so. In the
Netherlands the legal framework “Algemene douanewet” (hereafter ADW) ensures the
embedding of Union customs law in the national legal order. The ADW contains inter alia
provisions on the functioning and authorities of the Dutch Customs Administration,
sanctions, penalties and where required detailed rules for implementation of the UCC.
Further detailed implementation of the ADW is to be found in the “Algemeen Douanebesluit”
(herafter ADB) and in the “Algemene Douane Regeling” (herafter ADR).

42
5.2 Customs formalities on entry and import

Where the previous section discussed the overarching legal framework, it is now time
to turn to the actual formalities on entry and import in more detail. For convenience of the
reader, Figure 11 depicts the major building blocks of the customs formalities on entry. As
can be seen in the diagram, customs formalities can be dissected in five main building blocks.
These building blocks will be addressed in subsequent sections.

Figure 11; Overview of customs procedures for containers arriving

5.2.1 Entry Summary Declaration

Over the last two decades the focal point of customs policy in the EU has shifted from the
traditional fiscal objectives towards safety and security objectives. As can be read in the
preamble of the UCC (28) a common risk management framework is introduced to minimize
the risks to the Union, its citizens and its trading partners. Mandatory pre-notification of
goods entry in the Union is an important input for the assessments of risks to the achievement
of the common objectives of the customs administrations of the EU member states.
The Union Customs Code prescribes that goods being carried into the territory of the
Customs Union shall be covered by an Entry Summary Declaration (UCC article 127). This
entry summary declaration is the act whereby a person informs the customs authorities in the
prescribed form and manner and within a specific time limit, that goods are to be brought into
the territory of the Union (UCC article 5). This declaration is to be lodged prior to entry of
goods into the territory of the union and is intended to enable the customs authorities to
conduct risk analysis.
The obligation to lodge the entry summary declaration rests with the carrier (UCC
article 127). Within the context of this customs formality this is the person who brings the
goods, or who assumes responsibility for the carriage of the goods, into the customs territory
of the Union. Notwithstanding this obligation of the carrier, other the other persons named in
UCC article 127 may lodge the entry summary declaration instead.

43
The entry summary declaration for containerized cargo must be lodged at latest 24
hours before commencement of loading of the container on the vessel on which it will be
brought into the customs territory of the Union (Article 105 UCC DA). The entry summary
declaration contains all necessary data for analysis of safety and security risks (UCC Article
127).
Within the UCC, “risk” is defined as the likelihood and the impact of an event
occurring with regard to the entry which would prevent correct application of Union or
national measures, compromise the financial interests of the Union and its member states, or
pose a threat to the safety and security of the Union and its residents, to human or plant
health, to the environment or to consumers. (UCC article 5)
The risk analysis before entry is based on the data provided in the entry summary
declaration and is carried out by the customs office of first entry, primarily for safety and
security purposes (UCC article 128).
In practical terms this means that, when goods are brought into the territory of the
customs union by a vessel that is calling at more than one port in this territory, the ENS is to
be lodged at the customs office of first entry. This customs office of first entry is responsible
for the risk analysis on the entry of the goods listed in the entry summary declaration. The
risk assessment, that is conducted for safety and security purposes, can have four different
outcomes, being the risk levels A to C (as explained in Table 3) or no identified risk.

Risk type Risk treatment Reference

A “Do not load” message to carrier and declarant UCC DA


Article 187 (3)

B The customs office of first entry shall take prohibitive UCC DA


action
Article 187 (4b)

C Goods are subject to customs control at the customs UCC DA


office where the container is to be discharged
Article 187 (4c)

Table 3; Risk treatments based on ENS

In case the customs office of first entry identifies a risk for the goods carried on the
arriving container vessel, it should pass on the results of the risk analysis to the relevant
customs offices, so that these goods could be subject to customs control upon their arrival
(risk type B) in the territory of the customs union or upon scheduled discharge (risk type C).

44
For containerized cargo that is brought into the Union by sea, the customs authorities
shall complete the risk analysis within 24 hours of the receipt of the entry summary
declaration. The Customs authorities shall register the entry summary declaration upon its
receipt and shall notify the party that has lodged the declaration of its registration
immediately and shall communicate a master reference number and the date of registration to
that person (UCC IA Article 185).
The results of the risk analysis are uploaded in the Import Control System (ICS). This
is the EU system for lodging, handling and processing of entry summary declarations in
advance of the arrival of goods. The basic steps in the process are depicted in Figure 12,
which is retrieved from the website of the Dutch Customs Administration1.

Figure 12; Risk analysis at the customs office of first entry (www.belastingdienst.nl)

1
The “syntax” of the flow diagram is not completely accurate, but in this instance it is only
included to give a general overview of the process at the customs office of first entry.

45
Article 38 (6) UCC and Article 24 (3) UCC DA state that "where an AEO lodges a
temporary storage declaration or a customs declaration in accordance with Article 171 of the
Code, the customs office competent to receive that temporary storage declaration or that
customs declaration shall, where the consignment has been selected for customs control,
notify the AEO of that fact. That notification shall take place before the presentation of the
goods to customs. That notification shall not be provided where it may jeopardise the controls
to be carried out or the results thereof." This notification that goods have been selected for
control is sent 72 hours in advance of the expected time of arrival.

In the table below the relevant legal provisions for entry summary declarations are
listed for convenience of the reader.

Entry Summary Declaration

Source Articles

UCC 5, 9, 127 - 132

UCC IA 182 – 188

UCC DA 24 (2), 104 – 113

Table 4; Relevant legal provisions for ENS

5.2.2 Entry in the customs territory

To allow correct application of customs legislation, article 2:1 ADW and ADR 2:0
provide that, at minimum 2 hours in advance of the arrival of the vessel in the port resorting
under the customs office where the goods will be presented, the estimated time of arrival
shall be electronically notified to that customs office. This pre-arrival notification for the sea
going vessel includes the information of the IMO/FAL1 general declaration and shall
additionally state the estimated time of arrival.
Based on article 133 of the UCC a second notification is to be made upon arrival. The
operator of the sea going vessel shall notify the customs of first entry upon arrival of the
means of transport. This second notification includes the actual time of arrival (ATA). This
ATA notification can be reported under reference to the temporary storage declaration
provided that this declaration has been lodged prior to the actual time of arrival of the vessel.

46
In the port of Rotterdam the port community system Portbase is used to facilitate the
electronic notifications (Portbase “Melding Schip 2.0”).
No ATA notification shall be required when the goods have temporarily left the
customs territory of the Union while moving between two points in that territory provided
that they have been carried by direct route without a stop outside the customs territory.

In the table below the relevant legal provisions for arrival notifications have been
listed.

(Pre-) Arrival notification

Source Articles

UCC 133, 136

UCC IA 189

ADW 2:1

ADR 2:0

Table 5; Relevant legal provisions for (pre-) arrival notification

Goods entering the territory of the customs union are subject to customs supervision
(safety, security, fiscal) until their customs status is determined. As soon as their customs
status is established as Union goods, the goods will no longer be subject to customs
supervision. Non-Union goods will remain under customs supervision until their customs
status is changed to Union goods, or they are taken out of the customs territory of the Union
or until they are destroyed.
In the Table 6 below the relevant legal provisions for arrival notifications have been
listed.

47
Customs Status

Source Articles

UCC 5, 22-24, 153-157

UCC IA 194-216

UCC DA 119-133

Table 6; Relevant legal provisions for customs status

From their time of entry in the customs territory of the Union, the goods may be
subject to customs controls (UCC Article 134), whereas supervision means: “action taken in
general by the customs authorities with a view to ensuring that customs legislation and,

where appropriate, other provisions applicable to goods subject to such action are observed”.

Within this context “Customs controls” means the specific acts performed by the
customs authorities in order to ensure compliance with the customs legislation and other
legislation governing the entry, exit, transit, movement, storage and end-use of goods moved
between the customs territory of the Union and countries or territories outside that territory,
and the presence and movement within the customs territory of the Union of non-Union
goods and goods placed under the end-use procedure”
Subsequently, the person who brings the goods in the territory of the union shall
convey them without delay, by the route specified by the customs authorities and in
accordance with their instructions, if any, to the customs office designated by the customs
authorities, or to any other place designated or approved by those authorities (UCC Article
135). In the context of this research project, this is a temporary storage facility of the
container terminal operator.

5.2.3 Presentation, unloading and examination

Goods brought into the customs territory of the Union and that will be discharged,
unloaded or trans-shipped shall be presented to customs immediately upon their arrival at the
designated customs office or any other place designated or approved by the customs
authorities (UCC Article 139).
"Presentation of goods to customs" within the context of this research project means
the notification to the customs authorities of the arrival of goods at the temporary storage

48
facility (UCC DA Article 115). Article 144 UCC introduces the legal fiction that the goods
are in temporary storage from the moment that the goods have been presented to customs.
For container vessels the act of presentation of goods by the carrier at temporary
storage facility may be done in one instance for all the containers that are to be unloaded
from the vessel. The carrier or a party acting on his behalf shall perform the presentation of
the goods. Notwithstanding this obligation the presentation can also be effected instead by
the holder of an authorisation for the operation of storage facilities.
The act of presentation shall be effected through digital means of communication
(Algemene Douane Regelening article 2.2). In practice this “digital” notification of arrival is
submitted through the Rotterdam Port Community System Portbase.
Article 140 provides that containers shall only be unloaded from the vessel with
approval of customs administration. Provided that risk analysis did not indicate immediate
safety or security risks, the Dutch Customs Administration tacitly allows unloading of the
container1.
The customs administration may at any time require the goods to be unloaded and
unpacked for the purpose of examining them or taking samples (UCC Article 140).
In the table below the relevant legal provisions for arrival notifications have been
listed.

Presentation, unloading and examination

Source Articles

UCC 139-143 (144)

UCC IA 190

UCC DA 115

ADR 2:2

Table 7; Relevant legal provisions for presentation, unloading and examination

1
Source: www.belastingdienst.nl, handboek douane “binnenbrengen via zee”, accessed
September 21 2017

49
5.2.4 Temporary storage

As indicated previously, arriving goods are in temporary storage by legal fiction from
the moment that they have been presented to customs. Temporary storage means the situation
of non-Union goods temporarily stored under customs supervision in the period between their
presentation to customs and their placing under a customs procedure or re-export. A
temporary storage facility is a customs approved place, where non-Union goods are placed in
storage under customs supervision prior to being released for free circulation, placed under a
customs procedure, re-exported or abandoned to the state.
The facility in which the goods are stored must be authorised by the customs
authorities as a temporary storage facility (UCC 144 and 148) and the conditions under which
the authorization is permitted are set out in the authorization. Authorization for temporary
storage will be granted only to persons who satisfy the conditions in UCC article 148 (2).
Two of these conditions are that the holder of the authorization provides necessary assurance
of the proper conduct of the operations and keeps appropriate records in a form approved by
the customs authorities. These records shall contain all the information and particulars as set
out in UCC DA Article 116. Amongst others, this information includes reference to the
temporary storage declaration and reference to the “corresponding” end of temporary storage.
The holder of the authorization shall ensure that the goods will not be removed from customs
supervision. The Unamar arrest (C140/104) the ECJ made clear that the holder of the
authorization is responsible to fulfil the obligations arising from the storage of good in
temporary storage and that a customs debt is incurred when the goods are removed from
customs supervision.
Non-Union goods presented to customs shall be covered by a temporary storage
declaration1.
Article UCC 145 provides that the temporary storage declaration may also be used for
the purpose of the notification of arrival referred to in UCC Article 133 and for presentation
of the goods to customs referred to in UCC article 139. In practice this means that, in case the
Port of Rotterdam is the first port of call in the customs territory in of the European Union,

1
In Dutch practice this is often referred to as SATO (Summiere Aangifte Tijdelijke Opslag)
or SAL (Summiere Aangifte Lossen)

50
the temporary storage declaration is also used for the purpose of the notification of arrival
and for presentation of the goods to customs. In case the port of Rotterdam is not the first port
of call and the customs office of first entry is located in another member state, the temporary
storage declaration is used for presentation of the goods to the customs office but not for
notification of arrival in the Union.
The temporary storage declaration is the act whereby the declarant indicates that
goods are in temporary storage. This declaration references to the Entry Summary
Declarations that were lodged prior to the loading of the containers on the vessel at the port
of origin. The declaration for temporary storage can be lodged at the latest at the moment of
presentation of the goods.
Storage in the temporary storage facility starts from the time of the presentation of
goods to customs and can last up to no more than 90 days. If the goods in temporary storage
are not placed under a customs procedure within this time limit, this will incur a customs debt
pursuant to article UCC article 79.
The carrier, a person acting on his behalf or the holder of the license of the temporary
storage facility, which is mostly the terminal operator, can lodge the temporary storage
declaration.

Temporary storage

Source Articles

UCC 5, 11, 17, 144-152

UCC IA 191-193

UCC DA 115-118

Table 8; Relevant legal provisions for temporary storage

51
5.2.5 Placing the goods under a customs procedure or re-export

From the definition of temporary storage, it follows that temporary storage of goods
ends at the moment that the goods are placed under a customs procedure or re-exported (UCC
art. 5: 17). Non-union goods arriving at a port within the customs union territory can be
placed under any of following procedures in accordance with the UCC:

- release for free circulation;


- special procedures; or
- re-export

Without discussing the substance of the different customs procedures, this section is
focused on the process of placing goods under customs procedures, also referred to as
customs formalities (UCC art. 5: 8).
For all goods intended to be placed under a customs procedure, except for the free
zone procedure, a customs declaration appropriate for the particular procedure must be
lodged (UCC Art. 158). In general, this declaration may be lodged by any person who is able
to have the goods presented to customs and who is able to provide all of the information
which is required for the application of the provisions governing the customs procedure in
respect of which the goods are declared (UCC Art. 170). UCC art. 172 provides that customs
declarations that are compliant with the provisions applying to all customs declarations shall
be accepted immediately. The date on which the declaration is accepted is, unless provided
otherwise, the date used for the application of the provisions governing the customs
procedure. In case the declarant is authorized to use a simplified declaration, the moment of
acceptance is the moment the goods are entered in the records. This moment of entry in the
records is the deemed acceptance through legal fiction. A customs declaration which has
been accepted may be verified by the customs authorities. This verification can inter alia
entail examining of the declaration and supporting documents and examination of the goods
(UCC art. 188). Where the conditions for placing the goods under the procedure are fulfilled
and provided that any restriction has been applied and the goods are not subject to any
prohibition the customs authorities will release the goods as soon as the particulars in the
customs declaration have been verified or are accepted without verification. This release of

52
goods is the act whereby the customs authorities make the goods available for the purposes
specified for the customs procedure under which they are placed.
The moment that the customs declaration is accepted is of particular importance.
From the moment that the declaration is accepted, the provisions of the customs procedure in
respect of which the declaration was lodged apply. This acceptance thereby also marks the
end of temporary storage of the goods. Except for the cases where the customs declaration
takes form of an entry in the declarants’ record1, the customs authorities will notify the
declarant of the acceptance of the customs declaration and will provide him with a Master
Reference Number (MRN) for that declaration and the date of acceptance (UCC IA Art. 226).

5.2.6 Conclusion

The preceding sections provide an overarching view on customs formalities for


containerized goods arriving at the port. In this section the formalities that have been
discussed in previous sections will be sifted through to isolate the event(s) or action(s)
important for further analysis. The aim is to point out relevant steps or events from which can
be measured to which extend containers are delayed by customs procedures. Figure 13 on
page 55 presents an overview and sequence of customs formalities.
Goods that are brought into the territory of the customs union are from their time of
entry subject to customs supervision and may be subject to customs controls until their
customs status is established. The goods are (shall be) under customs supervision for as long
as is necessary to establish their customs status. When the goods have not been established to
be Union goods, the goods will have the non-Union status. Goods with a non-Union status
remain under customs supervision until the status is changed to the Union status, the goods
have been taken out of the customs territory of the Union or destroyed. Union goods shall not
be under supervision, except for situations where the goods are assigned to the end-use
procedure.
At the moment of arrival of the container vessel at the port terminal, the arriving non-
Union goods that will be unloaded or transshipped must be presented to the customs

1
In UCC IA Art. 226 also oral declarations are accepted, but this is not applicable for
containerized cargo.

53
administration. From the moment that the goods have been presented to the customs
administration, the goods are in temporary storage by legal fiction.
Operation of the temporary storage facility requires authorization from the customs
authorities. The container terminal operator is the holder of the authorization and the person
storing the goods in a place approved by the customs authorities. As holder of the
authorization the terminal operator shall ensure that the goods are not removed from customs
supervision whilst the goods are in temporary storage.
The temporary storage of goods ends when the goods are placed under a customs
procedure or re-exported. For all goods intended to be placed under a customs procedure,
except for the free zone procedure, a customs declaration appropriate for the particular
procedure must be lodged. From the moment that this declaration is accepted, the provisions
of the customs procedure in respect of which the declaration was lodged apply. This
acceptance thereby also marks the moment from which the goods are no longer in temporary
storage. From the moment that the goods have been assigned to a customs procedure, the
condition that the goods shall be stored in the temporary storage facility (UCC Art. 147 (1))
no longer applies. At the moment that the goods are assigned to a customs procedure or re-
exported, the license holder of the temporary storage facility can allow movement of the
goods out of the temporary storage facility. The opposite applies as well: for as long as the
declaration for the subsequent customs procedure is not accepted, the terminal will keep the
container in the temporary storage facility because removal of the container from the facility
would count as unlawful removal from customs supervision which would incur a customs
debt.
The next sections will describe the business procedure for the release of containerized
cargo from the container terminal.

54
Overview and sequence of customs formalities

UCC Art 127 Entry UCC 145 Temporary UCC 133 Notification UCC 158 Acceptance of
summary declaration storage declaration of arrival customs declaration

2:1 ADW UCC 139 Presentation


Notification ETA of goods to customs

Min 24 Hr. Advice customs Min 2 Hr.


administration >72 Hr

55
Goods in temporary storage Customs procedure or re-export

Loading container Arrival Unloading


Departure
on vessel vessel Container from vessel
of vessel

Figure 13; Overview and sequence of customs formalities


5.3 Business process for hinterland transport

After fleshing out the customs formalities for the inbound flow of containerized cargo
in the previous section, this section will focus on the business procedures relating to
hinterland transport. More in particular, this section will concentrate on the logistics process
of hinterland transport, with the objective to sharpen the insight in hinterland transportation
processes, to the extent necessary for the realization of the objectives of this study.
When taking note of both practice and research (e.g. Van der Horst et. al, 2008 and
Verwaal et. al , 2008) it is clear that there are many actors involved in the process of
hinterland transport. One can think of terminal operating companies, forwarders, hinterland
transport providers and customs brokers. The layered supply chain model presented by
Oosterhout et al. (2000) gives a good impression of which parties can be involved with
moving the container from the port terminal to the final consignee.
178 Organizations and Flows in the Network

Fig. A.1 Layered model of global sypply chains [165].


Figure 14; Layered model of global supply chains (Source: Oosterhout et. al, 2000)
the physical group. Organizing the transport of a container can be done
However, by definition
in different models
ways. The are a simplification
shipping of reality,
line may outsource theascomplete
is the case with this
hinter-
land
model too. In transport
reality, operation
it is easy to notice to
thata for
logistics service
different provider,
transactions where network
a different several of
transportation modes and intermodal transshipment need to be coor-
participants is collaborating. The cooperation between different parties is governed by
dinated. Carrier inspired merchant haulage refers to haulage service
performed by a sub-contractor of the carrier. Merchant inspired carrier
haulage refers to carrier haulage56 service by a carrier nominated directly
by the shipper or receiver of the goods, but paid by the shipping line.
Organizations in the organizing group connect with the transaction
layer.
various factors, such as the delivery terms agreed between buyers and sellers, contractual
relations between different actors, the modality used for hinterland transport.
In the light of the research project before us, we take a closer look at the hinterland
activities in the “logistics” layer. In the previous chapter customs formalities for arriving
containers have been mapped out. From this overview the conclusion can be drawn that
customs formalities do not affect the lead-time of inland carriage itself, but that they do
influence the moment that inland carriage can commence. This fact is the reason for a closer
look at the procedures at the terminal.
Whilst container terminal processes can be different, the physical processes of the
terminals for inbound containers are largely the same. After arrival and berthing of the
container vessel at the quay of the terminal, the stevedore, or more precisely the container
terminal operator, discharges the containers from the vessel. Following the discharge from
the deep sea vessel, the container is moved into a stack where it will be stored until the
container is collected by the party performing the inland carriage. Based on pre-notification
of inland carriers, containers are moved from the stack to the area’s where the inland carriers
collect the containers. After positive identification of the inland carrier, the terminal operator
will load the container on the means of transport for inland carriage. The large container
terminals all offer the possibility to transship containers to either truck, train or barge.
The terminal operator will only allow an inland carrier to collect the container from
the terminal when there is a “customs release” and a “commercial release” for that container.
Containers will not be released from the terminal before the port terminal operator is satisfied
that the goods are assigned to a customs approved treatment or use and that the goods are not
blocked by customs for safety and security purposes. This is the “customs release” from the
perspective of the terminal operator, which was analyzed in more detail in the previous
section from the legal perspective. To understand the “commercial release”, a closer look at
business of the terminal operator is needed.
The port terminal operator is employed by the person responsible for discharge of the
containers from the arriving deep sea vessel. This can be either the carrier or the cargo
interest. Port terminal operators that handle containers are normally contracted by the carrier.
Niessen (2017) answers the question if transshipment falls within or outside the
definition of a contract of carriage. Under transport law, the contract of carriage covers the
time that the goods are in custody of the carrier. This is the time between the moment that the
goods are taken over by the carrier and the moment of delivery. During this period the carrier

57
is responsible and liable for any loss, damage or delay. Delivery within the legal definition is
the bilateral act where the carrier surrenders control over the cargo to the cargo interest who
in turn accepts control over the cargo. Delivery and discharge of containers is mostly not
coextensive; the containers that have been discharged are normally stored on the terminal for
some time before delivery to the cargo interest takes place.
Where the contract of carriage is subject to the H(V)R1, the carrier is only
mandatorily liable during period from the time that the goods are loaded on, to the time that
they are discharged, from the ship. This period is also referred to as the “tackle to tackle
period”. This follows from the fact that the H(V)R only apply during this period. The rules
however do not attach to the time before loading and after discharge during which the goods
are in custody of the carrier. During this period the carrier is not subject to the mandatory
liability regime of the H(V)R. During this period the performance of the contract of carriage
is subject to national law. Carriers in most cases exclude any liability with the “before-and-
after- clause” where so permitted under national law. Where the contracts of carriage also
include a Himalaya clause, the port terminal operator can also rely on the before-and-after
clause, provided that the transshipment services fall within the scope of the contract of
carriage.
With the knowledge that the contract of carriage is operative until the moment that the
container is delivered to the cargo interest by the terminal operator who acts on behalf of a
sea carrier, we now take a closer look at the contract of carriage.

5.3.1 Contract of carriage

In most cases where goods require transport by sea, they have been sold by a seller to
a buyer. In these cases, the contract of carriage is ancillary to the contract of sale. Depending
on the delivery terms agreed in the contract of sale, the buyer or the seller (or parties acting
on their behalf) will assume the role of “shipper” and enter into a contract of carriage with the
carrier.

1
The Hague (Visby) Rules. The Hague Rules; The Brussels Convention for the Unification
of Certain Rules of Law relating to Bills of Lading of 25 August 1924. The Hague-Visby
Rules; the Hague Rules as amended by the Brussels Protocol of 23 February 1968.

58
Since the contract of carriage has direct influence on the procedure to release
containers from the port terminals, this section will focus on the contracts used for carriage of
containers.
Containers are predominately shipped through liner services. This means that ships
sail advertised schedules and call at the same ports in the same sequence during every
“rotation”.
In the realm of contemporary container shipping, the contract of carriage for
containers is attested by either a bill of lading or a sea waybill. These two documents both
serve as evidence of a contract of carriage and have similar function, but there are differences
as well. These differences affect the commercial release by the carrier at the container
terminal in the port of discharge. Therefor it is necessary to understand the use and
functioning of both the sea waybill and the bill of lading.

5.3.2 Bill of Lading

As indicated before, it is the shipper, who may be the buyer or the seller depending on
the terms of sale or parties on their behalf, who enters into contract with the carrier. The Bill
of Lading is a common used document of carriage in the container shipping industry.
This (liner) Bill of Lading can take different forms since most shipping lines use their
own standard documents. Nonetheless the main functions of the bill of lading are the same
throughout the container shipping industry. Each bill of lading will have the following three
basic functions. The bill of lading is:

- the receipt for the goods shipped;


- the evidence of the contract of carriage;
- a document of title;
- a means for identification of the person entitled to take delivery

The first and original function of the bill of lading is that it is the receipt for the
goods, issued by the carrier. The bill of lading will therefore include statements on the
cargoes received for shipment by the carrier, such as the description of the goods, quantity,
container numbers, seal numbers and the apparent order and condition of the goods. These
qualifications are effectively made by the shipper during the booking process and accepted by

59
the carrier. Because third parties that take delivery of the container can rely on these
statements, it is normally in the interest of the carrier for the bill of lading of the goods to say
as little as possible about the goods shipped. It is therefore that it is common that
qualifications such as “said to contain” (STC) or “full container load” (FCL) or “Shippers
load stow and count” (SLAC) are inserted to indicate that the container was packed by the
shipper and that the carrier was unable to check the contents of the container. In the business
of container shipping the carrier will usually only acknowledge without reservation the
receipt of the container and the apparent good condition of the container itself.
The second function of the bill of lading is that it evidences the contract of carriage. It
is not on itself the contract of carriage, but merely the “excellent” evidence of it. The actual
contract can be made before the goods are delivered in the hands of the carrier or an agent
acting on his behalf, typically during the booking process. However, when the bill of lading
is in the hands of an endorsee it provides conclusive evidence on the particulars of the cargo.
The freight clauses on the B/L are binding on the carrier and on the third party holder of the
B/L even when the amount of freight is not mentioned. Examples of this clause are “Freight
Payable at Destination” or “Freight Prepaid”. Freight clauses are of particular importance in
relation to the release procedure in the port of destination, because the carrier can demand to
be paid before surrendering control over the goods.
The third function of the bill of lading is that it is a document of title. As a document
of title the B/L “embodies the exclusive right to take delivery of goods” and it can also be
used for the symbolic transfer of control over and ownership of goods for as long as the
goods have not been delivered by the carrier. It is the duty of the carrier to surrender control
over the goods to the holder of the Bill of lading when he surrenders the original and duly
endorsed Bill of Lading to the carrier. A straight B/L is named to the consignee directly and
is non negotiable (transferable). A B/L “to the order of” or “to bearer” can be transferred by
endorsement. The function of “document of title” is of importance to the release procedure in
the port of destination because the carrier will not surrender control over the goods when the
B/L has not been tendered by the party entitled to take delivery of the goods.
The fourth function of the B/L is the identification of the party that is entitled to take
delivery of the cargo. The consignee can be identified by endorsement of the original B/L.
The carrier can deliver the goods to the first party that surrenders the original B/L that is duly
endorsed to the party that presents the B/L.

60
Another aspect with significant importance to the release procedure of the terminal
operator is the right of the carrier to exercise a lien over the cargo of others. (Girvin, 2011).
The carriers’ lien is the right of the carrier to retain the cargo in his possession that belongs to
another. It is usual for Bills of Lading that express provisions for the right of lien are
included. As a typical example the Conlinebill 2016 includes: “The Carrier shall have a lien
on all cargo for any amount due under this contract and the costs of recovering the same and
shall be entitled to sell the cargo privately or by auction to satisfy any such claims.” By
result, the carrier will only notify the port terminal operator that the container may be
released after freight and ancillary charges such as demurrage and detention have been
collected in full.
The B/L is mostly used in combination with international contracts of sale where
buyers and sellers agree “cash against documents” (CAD). In these cases the undertakes that
he will present a set of documents, including the B/L, to the buyer or to a bank appointed by
the buyer. When the buyer or the bank appointed by the buyer establishes that the documents
are in conformity with the contract of sale and pays for the goods, the B/L is transferred to
the buyer and becomes the owner of the goods to which the B/L relates (Zwitser, 2012).

5.3.3 Sea Waybill

The Sea Waybill is similar to the Bill of lading, but not the same. It fulfills three out
of the four functions of the Bill of lading. The sea waybill is used in maritime commerce as a
receipt for goods loaded aboard the carrying vessel in the port of origin. Next to the function
of a receipt, the sea waybill also evidences the contract of carriage and it identifies the person
to whom delivery of the goods is to be made by the carrier in accordance with that contract1.
Unlike the bill of lading, the sea waybill is not a negotiable document nor is it a document of
title.
Because the sea waybill is a non-negotiable and because it is not a document of title,
the document cannot be used in transactions in which payment is made through documentary
credit or in transactions where cargo is sold during transit. Only the party that is identified as
the consignee or parties acting on behalf of the consignee can take delivery of the cargo. It is

1
UK Carriage of goods by sea Act 1992.

61
not uncommon to find that parties to the international contract of sale do not require a
negotiable document of title. This can be the case for transactions between parties with a
long-standing relation or for intra-group transactions of multi-national companies (Girvin,
2011).
The upside of the use of the sea waybill is the advantage that there is no need for the
consignee to surrender the sea waybill to the carrier in order to take delivery of the container
in the port of discharge. It suffices for the consignee to positively identify himself as the party
identified as such in the sea waybill. There is no risk that the vessel arrives in advance of the
documents.
Just as Bills of Lading, Sea Waybills normally include express conditions on the
carriers’ right of lien. Although the content of the clauses varies for different carriers, the
effect on the release procedure is normally the same as for situations where a B/L is issued.
The carrier will retain possession for as long as not all freight and ancillary charges have
been collected in full.

5.3.4 Commercial release of containers

After discussion of the relation between the carrier and the port terminal operator and
after discussion of the two most common contracts of carriage in the business of container
shipping, one can now understand the background of the commercial release that is submitted
by the carrier to the operator of the container terminal that that acts as his servant.
The port terminal operator performs stevedoring duties as a servant to the carrier. The
carrier will only submit the commercial release message to the port terminal operator when
freight and ancillary charges have been disbursed in full and when a duly endorsed original
B/L is surrendered by the holder. For containers shipped with a Sea Waybill the consignee
does not need to present the original copy of the bill in order to obtain delivery. The table
below briefly recapitulates the requirements for the commercial release.

62
Document Freight collected Document surrendered Consignee Identified

Bill of Lading Yes Yes Yes

Sea Waybill Yes No Yes

Figure 15; Requirements for commercial release

Days before arrival of the container vessel in the port of discharge, the notify party on
the Sea Waybill or B/L will receive a pre-arrival notice. The notify party can be the
consignee itself or a party acting on behalf of the consignee, such as a forwarding agent. This
notice of pre-arrival will include notification of freight and ancillary charges due.
As soon as freight and ancillary charges have been collected in full by the ships agent
in the port of discharge, and the B/L has been surrendered by the cargo interest, he will send
the container release massage to the notify party. This message includes all the particulars
necessary for the pick up of the container from the terminal, including the release code. This
release code, in praxis often referred to as pincode, is also communicated to the terminal
operator.
The inland carrier will report at the gate the container number and the release code.
When the release code received from the inland carrier matches the release code from the
ships agent, the container will be released from the terminal, provided that the other criteria
for release have been met as well. This process is depicted in Figure 16 below.

Notice of pre-arrival (and invoice, if applicable)

Carrier Payment of freight and B/L Surrender (if applicable)


Consignee /

(Ships Agent) Notify party


Container release order (incl. release code)
Time

Release code Ch Release code


ec
k

Release code

Terminal Inland
Operator Container Carrier
Container

Figure 16; Procedure for commercial release

63
5.3.5 Conclusion

The sections of this chapter dealt with the business procedures of port terminal
operators. In particular the requirements for the commercial release were brought in focus. It
was identified that, for arriving containers, transshipment at the port terminal is executed
under the contract of carriage. The carrier contracts the port terminal operator for stevedoring
duties. To understand the backgrounds of the commercial release of containers, the contract
of carriage was studied in more detail. Through discussion of the two most common contracts
of carriage for carriage of goods by sea, the commercial requirements for release were
brought to the foreground.

5.4 Planning hinterland transport

Planning of hinterland transport is dependent on various aspects. Aside from the


selection of the transport modality, planning of hinterland transport is in general dependent
on availability of resources for the transport itself, the availability and release status of the
container that is to be collected and the assignment of a time slot for pick up by the terminal
operator to the hinterland transport operator.
The procedure1 at RWG and other Rotterdam based terminals is that hinterland
transport operators must pre-announce pick up of containers and that time slots for pick up of
containers are confirmed by the terminal operator.
For trains and barges, the hinterland transport operators must notify the loading list to
the terminal at latest 12 hours prior to the estimated time of arrival (ETA) of the barge or
train. Pick up of individual containers on the loading list will be cancelled by the terminal in
case the “required conditions” for pick up of the container have not been fulfilled 2 hours
prior to ETA of the train or barge. In practical terms this means that when the container is not
released 2 hours before ETA of the means of transport for inland carriage that the terminal
will cancel pick up of the container. These cancellations subsequently cause transport
capacity to be unused.

1
https://rwgservices.rwg.nl/Information/OperationalInformation , accessed on August 16
2018. The information is included in annex B

64
For trucks, transport operators can plan 2-hour slots for pick-up through the truck
appointment system. In case the container is not released one hour before the start of the
planned slot, the appointment will be cancelled by the terminal.
In response to the terminal procedures for pick up of containers, hinterland transport
operators in the majority of cases first await the container to be released after which they start
planning the pick up of the container from the terminal. This sequence can also be witnessed
in the diagram of the Rotterdam Port Community System operator “Portbase” that is included
in annex C. Use of this sequence in practice could also be validated through discussion with
the operations manager of an inland terminal that also operates a barge service between the
port of Rotterdam and the inland terminal in Hengelo (CTT). Before adding inbound
containers to loading lists, CTT awaits the confirmation that the containers are released.

5.5 Conclusion

This chapter untangles the process by which inbound containers are released from the
terminal into the custody of the hinterland carrier. The release of containers is governed by
the terminal operator against the background of operational aspects, customs law and the
obligations and liabilities that arise from the contract of carriage (Figure 17 on page 67).

In summary, the release of containers from a port terminal is based on six criteria:

1. The container is available on the terminal


2. The B/L has been surrendered by the cargo interest to the carrier (with B/L )
3. Freight and ancillary charges due have been disbursed in full
4. The party entitled to take delivery of the cargo has been identified
5. Absence of a customs block for inspection or found conform after inspection
6. The cargo has been assigned to a customs approved treatment or use.

Criteria 2, 3 and 4 have been discussed in section 5.3 and find their background in the
contract of carriage by sea. The carrier will require that these requirements are fulfilled to his
satisfaction prior to the release of the container from the terminal. Delivery without
fulfillment of these criteria would leave the carrier without the effective remedy to unpaid
freight and would create liability against the legitimate cargo interest as a result of releasing

65
the cargo to parties that are not entitled to take the delivery. The criterion that the B/L must
be surrendered by the cargo interest is only applicable where a B/L is used as contract of
carriage by sea.
Criteria 5 and 6 have been discussed in section 5.2 and are rooted in Customs Law.
Temporary storage of arriving goods ends when the goods have been assigned to a customs
procedure or when they are re-exported. As the holder of the authorization of the temporary
storage facility, the terminal operator would make himself liable to a customs debt through
non-compliance in case goods liable to import duty would be removed from the temporary
storage facility (customs supervision) before these have been assigned to a customs
procedure. The conditions set out in the authorization for the temporary storage facility
include the obligation to administer the reference to the customs procedure for all cargo
released from the temporary storage facility.
Procedures of the terminal operator prescribe that hinterland transport operators must
pre-announce pick up of containers and that time slots for pick-up are assigned by the
terminal operator. When containers are not released before the planned pick up, the pick up
reference is cancelled by the terminal operator. In pursuit of efficiency hinterland transport
operators therefor often await the confirmation of the container release before planning pick
up of containers. Due to the longer cut-off time of 12 hours for barges and trains this has
greater impact on these modalities.

66
Operational Customs Law Contract of carriage by sea

Positive identification of
Customs declaration B/L Surrendered Freight & Ancillary charges
Availability of container Absence of customs block party entitled to take
accepted (not for Sea Waybill) collected by carrier
delivery

67
Figure 17; Overview of container release criteria
“Customs Release” “Commercial Release”

Container Release
6 Data Collection

With better understanding of the customs regulatory framework and business


procedures that govern the release of containers from the terminal, this chapter now turns to
the collection of research data.
For this research project a dataset has been drawn from transactional data of port
terminal operator RWG. Through cooperation with the terminal operator and the Dutch
Customs administration, empirical data was made available for this thesis project.
In two sessions with the Customs Administration and RWG the research question was
introduced and discussed. Subsequently the terminal procedures for arriving containers were
discussed step by step, building a good understanding of relevant terminal operations and
creating a good insight in the structure of the transactional data of the terminal.
Similar to other terminal operators, RWG controls its terminal operations with a
Terminal Operating System (TOS). This information system holds all transactional data and
is used for control of terminal operations of RWG.
A condition set out in the authorization for operation of the temporary storage facility
is that RWG keeps appropriate records in a form approved by Dutch Customs. To fulfill this
requirement, RWG produces a monthly audit file from the information in the TOS that
includes all information and the particulars that enable the Dutch Customs administration to
supervise the operation of the temporary storage facility. In particular, this audit file includes
the identification of the goods stored on the terminal, their customs status and their
movements. The information for the monthly audit file is extracted from the TOS of RWG.
With permission of RWG, part of the data contained in this audit file from September
2017 was used as the data source for this thesis project. The Dutch Customs Administration
assisted with making the appropriate extraction of records containing the relevant attributes
for this thesis project. With use of the process mining application “Celonis”, data was
selected from the audit file to isolate the containers arriving by sea carriage that were, after
being discharged and stored on the terminal, released from the terminal into the custody of an
inland carrier. By making this selection all other transactions such as for export containers,
transshipment to other vessels etc. could be excluded from the data file. In total 21.758
unique “passage keys” where selected and extracted from the audit file, of which each
represents the passage of one container. Thus, the dataset includes information for all 21.758

68
containers that arrived at RWG by sea carriage and were released to an inland carrier in
September 2017. The dataset includes the following attributes for each container passage:

- the actual time that the individual container is discharged from the vessel
- the modality used for inland carriage
- the “type” of customs procedure
- the actual time that the customs documentation was received by the terminal
- the actual time that the container left the terminal for inland carriage

This study concentrates on the effect of variation in the lead time of customs
formalities on the time that containers dwell at the port terminal. The target population for
this research is not related to container terminals, since the independent variable (document
lead time) is driven by individual cargo interests and not by container terminals. The target
population consists of all the arriving full containers in the port of Rotterdam destined to
consignees in the hinterland.
The sample includes all full containers that arrived at the terminal of RWG in the
month September 2017. Although one could contest that the selection method for the sample
reduces the external validity of the research results, it is also possible to contest that this has
limited effect. It is unlikely that the selection criteria “container terminal” and “September
2017” have influence on the document lead time for individual containers from a large group
of cargo interests and as a matter of principal all individual containers from different cargo
interests had an equal chance to be selected.
The initial format of the data provided could not be analyzed with standard
applications such as Excel and SPSS because the file included multiple records for each
passage key – attribute combination. To overcome this obstacle the data was imported and
processed in Microsoft Access. Within this database application it was possible to transpose
the initial data to the final “research file” with 21.758 records in which each record includes a
unique passage key and all corresponding attributes. The output was subsequently verified
against the initial file and found to be correct.
As a result of the fact that the data in the research file is initially captured by RWG
for the purpose of customs supervision on the temporary storage facility, the quality of the
data is of good standard. Internal cross checks of the data in the file did not reveal incomplete
records or inconsistency (e.g. containers leaving the terminal before they have been

69
discharged from the vessel). One aspect that stood out during verification is that for many
arriving containers the customs documentation is already provided by the cargo interest to the
terminal before the container is discharged from the vessel. This could imply that, contrary to
UCC art. 172, the customs declarations were accepted by the Customs Administration prior
to the presentation of the goods to customs. This observation was recognized by both the
Customs Administration and RWG. This anomaly is the result of the fact that within the
customs administration the presentation of goods and acceptance of customs declarations are
managed in different administrative systems. The datafile however proved to be correct on
this point because it reflects the actual situation.
As an example for the data file the first 20 of in total 21.758 records of the file have
been included in appendix A. The table below describes the meaning of the different fields
per record in the datafile.

Field Name Description

Passage Key Unique numeric identifier for each container passage

ZIBI Date and time when container discharge from the vessel is
completed (detailed for each container)

LUAF Date and time when container physically leaves the terminal
for inland carriage

Modality Modality for inland carriage (Truck, Barge, Rail)

MDBI Date and time when customs document was assigned to that
specific passage key. Documents were received prior to
discharge of the container. In case the documents were
received prior to the moment that the container is discharged,
this field will show the same time as the time of container
discharge (MDBI=ZIBI). This field is blank if the documents
were received after discharge of the container.

MUDA Date and time when customs documents where received (for
all containers for which the documents where received after
discharge of the container). This field is blank for all passage
keys where the documents were received prior to discharge of
the container.

Documentreceipt Combination of the fields MDBI and MUDA. This field shows
the date and time that the customs documents were received.
For all passages for which documents were received prior to
discharge, this field will show the same date and time as ZIBI.

Document type RTO document type identifying the customs procedure used
(Release for free circulation, external transit, etc.)

70
7 Descriptive analysis

Drawing on the research objectives laid down in section 2, the knowledge of the
research subject gained in the section 4 and 5 and the research data that has been collected,
this chapter is dedicated to the analysis of the collected data in pursuit of the objectives of
this study.
As defined in chapter 2 the first objective is to establish the time effect of customs
formalities on the lead time of the hinterland transport process. In chapter 3 the conceptual
model was introduced and the two variables were explained. Both variables are continuous
and measured in hours.
After a first exploration of the information in the dataset in section 7.1, this chapter
will return to the propositions presented in chapter 3. Statistical inference testing will be used
to ascertain if there is, or if there is not, a relation between document lead time or dwell time.

7.1 First exploration of the dataset

The first exploration of the two variables is performed by creating histograms of the
document lead time and dwell time (Figure 18 and Figure 19). The mean dwell time in
sample n is 86,83 hours and the mean document lead-time in the sample is 69,26 hours. In
addition, a scatterplot is made (Figure 20), showing all individual containers as data points. It
is clearly recognizable that the condition dwell time ³ document lead time applies to all
individual instances in the sample as expected. The container terminal did not release
containers before the cargo interest notified the terminal that the goods were assigned to a
customs procedure.
The total sample includes 21.758 arriving containers of which 14.168 containers have
a document lead time of 0 hours. For these containers the terminal was notified that the goods
were assigned to a customs procedure prior to discharge of the container. In these cases the
document lead time does not prolongate the container dwell time. The container cannot be
delayed by document lead time because the document lead-time is 0. The remaining 7.590
have a document lead time that is greater than 0. In Table 9 the mean dwell time in n is
shown for cases with document lead time 0 and for cases with the document lead time greater
than 0. The containers in the sample with a document lead time greater than 0 on average
dwell 32 hours longer at the terminal.

71
Figure 18; Histogram of container dwell time

Figure 19; Histogram of Document lead time

Table 9; Mean Dwell time

72
Figure 20; Scatterplot of Document Lead time and Dwell Time

7.2 Association between document lead time and dwell time

The first question to answer is: is there evidence of a linear relationship between the
variables document lead-time and dwell time at the 0,001 level of significance? To answer
this research question a statistical inference test is performed.
The ‘strength’ of the relation between document lead time and dwell time in the
population N is expressed with Pearson’s correlation coefficient r. The strength of the
correlation coefficient in sample n is expressed with r. The probability for a type 1error, a
false claim that there is an association between the variables when there is none, is expressed
by a. The hypothesis for testing are defined as stated below:

H0: r = 0 (no correlation)


Ha: r ≠ 0 (correlation exists)
n = 7.590, a = 0,001

73
The test is performed by first calculating Pearson’s correlation coefficient for sample
n and then to test if the probability of a type 1 error is below 0,001. The calculation of
correlation coefficient r was calculated with SPSS.

X = Document Lead time (hours)


Y = Dwell time (hours)

r=
å XY - nXY
å X - nX å Y
2 2 2
- nY 2

The correlation coefficient r for sample n is 0,720, indicating that there is a strong
correlation between the variables of the cases within the sample. With a test statistic it is
calculated if H0 should be accepted or rejected at the significance level a of 0,001.

𝑟 0,720
𝑡 = = = 90,37
%1 − 0,5184
(
%1 − 𝑟
𝑛−2 7590 − 2

The calculated value for t is greater than critical value (3,291), which leads to the
conclusion that the null hypothesis is to be rejected and consequently that there is evidence of
a linear relationship r between the Document Lead time and Dwell time in population N at
the level of 0,1 % of significance.

7.3 Describing the relation between document lead time and dwell time

Within section 7.2 it was confirmed that there is a strong association between the
document lead time and the time that containers dwell at the port terminal. In this section this
association will be further explained by linear regression analysis. This analysis seeks to
explain the impact of changes in the document lead time on the dwell time. With a simple
linear regression model the linear relation between the document lead time and dwell time is
described by a linear function, assuming that the changes in dwell time are caused by changes
in document lead time. The population regression model is formulated as below.

74
𝑦 = 𝛽5 + 𝛽7 ∙ 𝑥 + 𝜀

Whereas:

y = dwell time in hours


𝛽5 = 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑦 𝑖𝑛𝑡𝑒𝑟𝑐𝑒𝑝𝑡
𝛽7 = 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑠𝑙𝑜𝑝𝑒 𝑐𝑜𝑒𝑓𝑓𝑖𝑐𝑖𝑒𝑛𝑡
𝑥 = 𝑑𝑜𝑐𝑢𝑚𝑒𝑛𝑡 𝑙𝑒𝑎𝑑 𝑡𝑖𝑚𝑒
𝜀 = 𝑟𝑎𝑛𝑑𝑜𝑚 𝑒𝑟𝑟𝑜𝑟 𝑡𝑒𝑟𝑚

The assumption is that the random error values are statistically independent and that
these values are normally distributed for any given document lead time and have constant
variance. Self-evidently this model assumes that the underlying relationship between the
dwell time and document lead time is linear. The scatter plot of the data (Figure 20) gives no
indication to assume otherwise.
The sample regression line estimates the population regression line for which the
formulation is similar to the formulation of the population regression model.

𝑦GH = 𝑏5 + 𝑏7 ∙ 𝑥H

The error term 𝜀H is not included in the formulation for the sample regression line
because the individual random error terms in the sample have a mean of 0. 𝑏5 is the estimated
dwell time when the document lead time is 0. 𝑏7 is the estimated change in dwell time
(hours) per hour increase of document lead time. The value for 𝑏7 is found through the least
squares equation.

∑(𝑥 − 𝑥̅ ) ∙ (𝑦 − 𝑦N)
𝑏7 =
∑(𝑥 − 𝑥̅ )(

The values for 𝑏5 are subsequently found through :

𝑏5 = 𝑦N − 𝑏7 ∙ 𝑥̅

The computation of the function for the regression line has been performed with use
of SPSS. Based on this calculation the sample regression line to estimate the population
regression line is formulated as:

75
𝐸𝑠𝑡𝑖𝑚𝑎𝑡𝑒𝑑 𝐷𝑤𝑒𝑙𝑙 𝑡𝑖𝑚𝑒 [ℎ𝑜𝑢𝑟] = 61,33 [ℎ𝑜𝑢𝑟] + 0,937 ∙ 𝑑𝑜𝑐𝑢𝑚𝑒𝑛𝑡 𝑙𝑒𝑎𝑑 𝑡𝑖𝑚𝑒[ℎ𝑜𝑢𝑟]

This means that 61,33 hours of the total dwell time is not explained by the document
lead time and that for each hour of increase in the document lead time the estimated dwell
time increases with 0,937 hours. The p value is below 0,000 which means that the fit of the
regression line is a statistically significantly better than the fit of a y-intercept only model.
A statistical measure for the “goodness of fit” of the regression line is the coefficient
of determination, also referred to as R-squared. This coefficient can be calculated based on
the sums of squares. The regression line sum of squares is the sum of squared differences
between individual data points and the regression line. The total sum of squares is the sum of
the squares of the differences between between the individual data points and the mean dwell
time.
𝑟𝑒𝑔𝑟𝑒𝑠𝑠𝑖𝑜𝑛 𝑙𝑖𝑛𝑒 𝑠𝑢𝑚 𝑜𝑓 𝑠𝑞𝑢𝑎𝑟𝑒𝑠
𝑐𝑜𝑒𝑓𝑓𝑖𝑐𝑖𝑒𝑛𝑡 𝑜𝑓 𝑑𝑒𝑡𝑒𝑟𝑚𝑖𝑛𝑎𝑡𝑖𝑜𝑛 =
𝑡𝑜𝑡𝑎𝑙 𝑠𝑢𝑚 𝑜𝑓 𝑠𝑞𝑢𝑎𝑟𝑒𝑠

The coefficient of determination was computed with SPSS. Within the sample 0,52
(r-squared) of the variation in the dwell time is explained by the variation of the document
lead time. Bearing in mind all the external factors that can influence the dwell time, that is a
clear indication that the document lead time is an important factor to explain the variation in
container dwell time.

7.4 The difference between the document lead time and dwell time.

As can be seen in Figure 21 (repeat of Figure 4 on page 15), there is a difference


between the document lead time and the dwell time. This difference is the time that elapses
between the document receipt and the moment that the container leaves the terminal (exit).
For purpose of convenience this period is defined as DT-DLT.

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Discharge Document Receipt Exit

Document Leadtime DT-DLT

Time

Dwell Time

Figure 21; Definition of document lead time and dwell time

The relation between the document lead time and DT-DLT is illustrated in Figure 22.
This graph shows the mean DT-DLT for the (binned) Document lead time. As can be seen in
the graph, there is not a strong relation between the document lead time and the mean DT-
DLT that would indicate inverse proportionality. Variation in the documentation lead time
does not have great impact on the mean DT-DLT.

Figure 22; Relation between Document lead time and DT-DLT

The question to answer is: is there evidence of a linear relationship between the
variables document lead-time and DT-DLT at the 0,001 level of significance? A statistical
inference test is performed to answer this question.

77
The ‘strength’ of the relation between document lead time and dwell time in the
population N is expressed with Pearson’s correlation coefficient r. The strength of the
correlation coefficient in sample n is expressed with r. The probability for a type 1error, a
false claim that there is an association between the variables when there is none, is expressed
by a. The hypothesis for testing are defined as stated below:

H0: r = 0 (no correlation)


Ha: r ≠ 0 (correlation exists)
n = 21.758, a = 0,001

The test is performed by first calculating Pearson’s correlation coefficient for sample
n and then to test if the probability of a type 1 error is below 0,001. The calculation of
correlation coefficient r was calculated with SPSS.

X = Document Lead time (hours)


Y = DT-DLT (hours)

r=
å XY - nXY
å X - nX å Y
2 2 2
- nY 2

The correlation coefficient r for sample n is -0,112, indicating that there is not a
strong correlation between the variables of the cases (containers) within the sample. With a
test statistic it is calculated if H0 should be accepted or rejected at the significance level a of
0,001.

𝑟 −0,112
𝑡 = = = −16,6241
%1 − 0,0125
(
%1 − 𝑟
𝑛−2 21758 − 2

The calculated value for t is smaller than the critical value (-3,291), which leads to the
conclusion that the null hypothesis is to be rejected and consequently that there is evidence of
a (weak) negative linear relationship r between the Document Lead time and DT-DLT in
population N at the level of 0,1 % of significance. Although the association between the

78
document lead time and DT-DLT is statistically significant (due to the large sample size), it
has little effect on the total dwell time as can also be witnessed in Figure 22. Although the
relation between the document lead time and DT-DLT is statistically significant, it is of low
relevance because the strength of the relation (expressed by the correlation coefficient) is
low. When looking at the Figure 22 one could also argue that that the relation is not linear at
all.
The time period that the container is stored at the terminal after the terminal operator
received the notification that the goods are assigned to a subsequent customs procedure is not
strongly affected by the document lead time. In other words: containers with long document
lead times on average are not collected substantially quicker after the terminal operator
received confirmation that these containers were assigned to subsequent customs procedures.
The inverse statement also holds. Containers with relatively short document lead times on
average are not collected substantially slower after the terminal operator received
confirmation that these containers were assigned to subsequent customs procedures. Where
the Dwell time is the sum of the document lead time and DT-DLT, the DT-DLT on average
is more or less constant. This is illustrated by Figure 23. The total height of each bar shows
the mean dwell time in hours and the colours depict the share of document lead time and DT-
DLT. This also helps to understand the correlation between document lead time and dwell
time and the outcome of the linear regression analysis of section 7.3.

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Figure 23; Mean document lead time and DT-DLT

The data set also includes the modality by which each individual container leaves the
terminal. Table 10 includes information on the modal split for the containers in the data set.
For each modality (Barge, Rail, Truck) the mean DT-DLT is included in the table. The
average time required for pick up of the container after the cargo interest has confirmed that
the container is assigned to a subsequent customs procedure is 69 hours. Containers that are
transported by truck are collected from the terminal on average 59 hours after document
receipt whereas containers that are transported by barge on average are collected 88 hours
after document receipt. The different modalities selected by the cargo interests (or parties
acting on their behalf) have greater impact on the DT-DLT than the document lead time. This
may be partially explained by the difference in cut-off times for the container release for
different modalities as explained in section 5.4.

Table 10; Average DT-DLT per modality

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8 Conclusions

This concluding chapter strings together the research findings offered in the preceding
chapters to answer the research questions that were at the basis of his research project. In
addition, it will expound on the relevance, validity and limitations of the research findings.
Before coming to the conclusions, the research questions will be briefly revisited.
In chapter 2 the research topic for this thesis was introduced. The overarching
objective of this research project is to research the effect of customs formalities on the lead
time of hinterland transport. This study is not about the disruptions caused by customs
controls but about the effect caused by customs formalities.

The research questions that are at the heart of this study were formulated as follows:

- Is there evidence that customs formalities can be associated with the lead time of
hinterland transport?
- To what extent do customs formalities increase the lead time of hinterland transport
(Days, hours) ?
- Is there a causal effect of customs formalities on hinterland transport lead time?

Because customs formalities do not influence the speed of hinterland transportation


itself, this research project focused on the process of transshipment in the port of Rotterdam.
While the dependent construct of this study was narrowed to the “dwell time” of containers at
the port terminal, it is still justifiable to make statements on the hinterland transport as a
whole (as explained in chapter 3). Based on the gained understanding of the legal,
commercial and operational backgrounds of the release procedure at the terminal, the
construct “document lead time” was introduced. This construct served as a measurable
parameter for customs formalities in this study. Subsequently the effect of “document lead
time” on “dwell time” was studied to explain the relation between customs formalities and
the lead time of hinterland transport.

81
8.1 Findings and conclusions

Through statistical analysis it was observed that containers with longer document lead
times dwell longer at the port terminal. Simple linear regression was used to describe this
relation and predicts that on average every “extra” hour for the document lead time ads 0,93
hour of dwell time.
It was also observed that there is no strong association between document lead time
and the time that elapses after the terminal operator is notified that the cargo is assigned to a
subsequent customs procedure until the moment that the container is collected from the
terminal (DT-DLT). Increase in document lead time cannot be associated with similar
reduction of DT-DLT. On average, a container dwells 69 hours at the terminal after the
terminal operator receives confirmation that the goods are assigned to a subsequent customs
procedure.
Although this type of research cannot produce indisputable evidence for causation,
the findings are in line with the qualitive analysis reported in chapter 5. Terminal operators
will not release containers before they have received confirmation that the goods are assigned
to a customs procedure and hinterland transport operators in general will not add containers
to loading lists when the container has not been released by the terminal operator. Only after
the release of the container by the terminal operator the hinterland transportation is included
in the planning of the transport operator. Port terminal procedures dictate that loading lists
must be submitted to the terminal 12 hours before ETA of barge or train and one hour before
pick up with a truck. This also partially explains the variation between modalities. Hinterland
transport operators use extra time to avoid unused transport capacity due to cancellations by
the port terminal operator (as explained in section 5.4). The uncertainty for the hinterland
transport operator that the container will be released before the cut-off time leads to longer
lead times.
From the above it follows that the time used for customs formalities is an important
factor of influence on the variation in the lead time of hinterland transport. Since customs
declarations that are compliant with the applicable legal requirements are to be accepted by
the customs administration immediately, this means that the document lead time is driven by
the actions of parties in the hinterland. The underlying cause is the time used by parties in the
hinterland to lodge the customs declaration and for notification of the terminal operator that
the goods are assigned to a subsequent customs procedure. Cargo interests, directly or

82
indirectly through parties acting on their behalf, influence the time that containers dwell in
the port terminal and consequently the hinterland transport lead time as a whole.
The findings above support and build on the conclusion of Ypsilantis (2016, p. 42)
that parties in the hinterland have considerable influence on dwell time of containers at a port
terminal. Dwell time is not only controlled by terminal operations, but is influenced by
factors out of control of the port terminal operators. Where Ypsilantis identifies that variation
in dwell time can be related to actions controlled by parties in the hinterland, this thesis
identifies handling of customs formalities as one of these actions.

8.2 Relevance

The findings reported above underpin the importance of integration of customs


formalities in supply chain operations. When the dwell time for hinterland transport of
inbound containers are being lengthened by customs formalities, this has detrimental effect
on merchants trading the goods and logistics service providers, in particular the port terminal
operators. On a macro economical scale these delays can be identified as a non-tariff barrier
to trade.
Section 4.1 shows that there is great attention of academics for the optimization of
port terminal operations and hinterland transport. The link with customs formalities received
less attention and is mostly limited to more general statements. Section 4.2 shows that
research in the domain of trade facilitation is mostly of macro-economic nature.
Consequently, this research in the domain of trade facilitation does not provide great detail on
the actual barriers it tries to overcome.
Against the background of the academic literature in the supply chain and trade
facilitation domain, the outcome of this study provides better insight in the relation between
supply chain operations and customs formalities. It supports the notion that exogenous factors
influence port terminal operations as suggested by Ypsilantis (2016). Furthermore, it provides
a more detailed bottom-up view on a non-tariff barrier to trade as called for by Granger
(2014).
The outcome of this study should also raise awareness under practitioners that the
handling of customs procedures directly affects their supply chain operations. Focus on the
document lead time for their inbound containers could reduce the time required for hinterland
transport and increase the reliability of the planned lead times. Hinterland transport planning

83
and handling of customs declarations are mutually dependent and therefor require to be
coordinated, especially when these activities are outsourced to different subcontractors.

8.3 Limitations and recommendations for further study

The findings of this study are based on operational data of container terminal operator
RWG. The data quality was of good standard and the dataset included 21.758 instances that
could be used for analysis. The dataset included all containers arriving with container vessels
with a destination in the hinterland in September 2017. As already indicated in chapter 6, one
could argue that the selection method for the sample reduces the external validity of the
research results. It is unlikely that the selection criteria “container terminal” and “September
2017” have influence on the document lead time for individual containers from a large group
of cargo interests and as a matter of principal all individual containers from different cargo
interests had an equal chance to be selected. The results are limited to inbound containers
with a destination in the hinterland. Another aspect to bear in mind is that RWG is one of the
newest terminals in the Rotterdam port and uses the most advanced technology. Information
exchange with parties in the hinterland is “routed” via the Rotterdam port community system
Portbase. Although this will have limited effect on the findings of this research, it could be
that specific terminal procedures such as the cut off time for the release of the container
create differences between terminals. Other aspects, such as great congestion at terminals
could reduce the dependency of the dwell time on the speed at which customs formalities are
completed.
This study focused on the relation between customs formalities and hinterland
transport and described the relation between these two phenomena. A recommendation for
further study is to conduct a case study research to compare containers with long and short
document lead times to identify the factors that support or hinder expeditious handling of
customs declarations by cargo interests or parties acting on their behalf. The outcome could
support practitioners to improve business procedures and processes.

84
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List of figures

Figure 1; Development of global container volumes.............................................................. 7


Figure 2; Layered model of global supply chains (Source: Oosterhout et. al, 2000) ............... 8
Figure 3; Thesis outline....................................................................................................... 12
Figure 4; Definition of document lead time and dwell time ................................................. 15
Figure 5; Conceptual model ................................................................................................ 16
Figure 6; Research stages .................................................................................................... 18
Figure 7; Integrated view of freight transport planning (Behdani et. al, 2016) ..................... 25
Figure 8; Trade cost diagnostics (Source: OECD, 2013)...................................................... 32
Figure 9 From cost components to trade diagnostics (Source: OECD, 2013) ....................... 33
Figure 10; The sources and hierarchy of EU Law (European Customs Code, Tom Walsh) .. 39
Figure 11; Overview of customs procedures for containers arriving .................................... 43
Figure 12; Risk analysis at the customs office of first entry (www.belastingdienst.nl) ......... 45
Figure 13; Overview and sequence of customs formalities .................................................. 55
Figure 14; Layered model of global supply chains (Source: Oosterhout et. al, 2000) ........... 56
Figure 15; Requirements for commercial release ................................................................. 63
Figure 16; Procedure for commercial release....................................................................... 63
Figure 17; Overview of container release criteria ................................................................ 67
Figure 18; Histogram of container dwell time ..................................................................... 72
Figure 19; Histogram of Document lead time ...................................................................... 72
Figure 20; Scatterplot of Document Lead time and Dwell Time .......................................... 73
Figure 21; Definition of document lead time and dwell time ............................................... 77
Figure 22; Relation between Document lead time and DT-DLT .......................................... 77
Figure 23; Mean document lead time and DT-DLT ............................................................. 80

88
List of tables

Table 1; Developments driving trade facilitation ................................................................. 30


Table 2; Comparison literature in Supply Chain and Trade Facilitation domain................... 38
Table 3; Risk treatments based on ENS ............................................................................... 44
Table 4; Relevant legal provisions for ENS ......................................................................... 46
Table 5; Relevant legal provisions for (pre-) arrival notification.......................................... 47
Table 6; Relevant legal provisions for customs status .......................................................... 48
Table 7; Relevant legal provisions for presentation, unloading and examination.................. 49
Table 8; Relevant legal provisions for temporary storage .................................................... 51
Table 9; Mean Dwell time................................................................................................... 72
Table 10; Average DT-DLT per modality ........................................................................... 80

89
Appendix A; Example data format for analysis

90
Appendix B; Terminal procedure RWG for pick up

Truck

RWG works with a so-called Truck Appointment System that consists of time slots of
2 hours. During the week, a grace period of 30 minutes is added after the time slot. Time slots
must also be booked during the evening and at night, between 20.00 and 06.00. However, it is
possible to enter the terminal throughout this entire period of time. The same applies for the
weekend period from Fridays 20.00 until Mondays 06.00.
Keep in mind that your appointment will be cancelled one hour before the start of the
booked time slot if the pre-announcement is not (entirely) correct. It is possible to book a
time slot within a slot up to one hour and 45 minutes (105 minutes) into that particular slot.
To be able to do this, though, all pre-announcement conditions have to be met within 15
minutes after you have booked the time slot. The truck visit needs to be pre-announced
through the Port Community System of Portbase. Click here for more information about the
pre-announcement.
Click here for the real-time occupancy of the time slots.
Barge

Pre-announcement for barge visits has to be done through Portbase. The pre-
announcement has to be done at least 48 hours before ETA. Click here for more information
about the pre-announcement. The designated window for the barge will be sent to you
latest 24 hours before ETA. The load list and discharge list must be sent to RWG at least 12
hours before ETA. For barge, a cut off of 2 hours before ETA applies.


Rail

Pre-announcement for train visits has to be done by means of the railway timetable.
The pre-announcement has to be done at least 48 hours before ETA. The load list and
discharge list can be accessed through Portbase. The designated window for the train will
be sent to you latest 24 hours before ETA. The load list and discharge list must be sent to
RWG at least 12 hours before ETA. For rail, a cut off of 2 hours before ETA applies.

91
Appendix C; Pre-notification via Portbase

92
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